Case: David v. Signal International, LLC

2:08-cv-01220 | U.S. District Court for the Eastern District of Louisiana

Filed Date: March 7, 2008

Case Ongoing

Clearinghouse coding complete

Case Summary

This is the first case filed in the Signal International cases.On Mar. 7, 2008, twelve Indian guestworkers recruited for work in the United States in exchange for green cards filed this class-action lawsuit in the U.S. District Court for the Eastern District of Louisiana. In the aftermath of Hurricane Katrina, plaintiffs were recruited to provide labor and services to defendant Signal International, a company based in Mississippi with operations in the Gulf Coast region, which was in the busine…

This is the first case filed in the Signal International cases.

On Mar. 7, 2008, twelve Indian guestworkers recruited for work in the United States in exchange for green cards filed this class-action lawsuit in the U.S. District Court for the Eastern District of Louisiana. In the aftermath of Hurricane Katrina, plaintiffs were recruited to provide labor and services to defendant Signal International, a company based in Mississippi with operations in the Gulf Coast region, which was in the business of providing repairs to offshore oil rigs. Plaintiffs alleged that defendant ran a fraudulent and coercive employment recruitment scheme.

Plaintiffs also named the following agents as co-defendants for their involvement in the scheme: Malvern C. Burnett, his law offices, and his Gulf Coast Immigration Law Center (New Orleans lawyers); Global Resources and Michael Pol (Mississippi-based recruiters); Dewan Consultants and Sachin Dewan (India-based recruiters); Indo-Amerisoft and Kurella Rao (New Orleans labor brokers); and J&M Associates (Mississippi-based labor brokers). Plaintiffs later added others, including Billy Wilks of J&M.

Plaintiffs asserted class action claims, on behalf of a class of over 500 workers, under the Trafficking Victims Protection Act (TVPA) (18 U.S.C. § 1589 (forced labor) and 18 U.S.C. § 1590 (trafficking)), the Racketeer Influenced Corrupt Organizations (RICO) Act (18 U.S.C. § 1962), the Civil Rights Act of 1866 (42 U.S.C. § 1981), and the Ku Klux Klan Act of 1871 (42 U.S.C. § 1985). Plaintiffs also asserted collective action claims under the Fair Labor Standards Act (FLSA), and claims for damages under a theory of fraud, negligent misrepresentation, and breach of contract. Several plaintiffs also brought individual claims of false imprisonment, assault, battery, intentional infliction of emotional distress and/or negligent infliction of emotional distress. Plaintiffs were represented by the ACLU, the Southern Poverty Law Center, the Asian American Legal Defense and Education Fund, the Louisiana Justice Institute, and attorneys from several large private law firms.

Plaintiffs alleged that they paid recruiters as much as $20,000 each for travel, visa, and recruitment fees, but upon arrival in the United States found out they would not receive the green cards promised to them. Instead, plaintiffs were allegedly forced to pay additional fees of $1,050 per month to live in racially segregated labor camps in Mississippi and Texas with security guards and oppressive rules, and were subject to squalid living conditions, more dangerous and less desirable work assignments than those given to American workers, and threats of both legal and physical harm if they complained about the conditions or decided not to provide labor. Defendant Signal filed a third-party complaint alleging that it did not misrepresent the immigration incentives to any of the plaintiffs, and that it was relying on the recruiters and their lawyers to lawfully provide foreign workers.

During discovery, Magistrate Judge Daniel Knowles granted a protective order in Apr. 2009 prohibiting inquiries into current immigration status, current address of any plaintiff, or employers of any plaintiff after they left Signal. Magistrate Judge Knowles held that the damage and prejudice that would result from discovery into current immigration status outweighed its probative value, and noted the order was necessary since undocumented litigants would likely drop out of the suit if forced to produce immigration documents. In Aug. 2010, Magistrate Judge Knowles denied a motion by Signal to compel production of T- and U-visa applications, since it would necessarily result in an inquiry into the plaintiffs' current immigration status.

On Nov. 10, 2010, the District Court (Judge Jay Zainey) granted Signal's motion to dismiss plaintiffs' claim for class certification for injunctive relief, and plaintiffs filed a supplemental motion to certify the class for claims under the TVPA, Civil Rights Act, RICO Act, and KKK Act. Discovery continued for two more years.

On Jan. 3, 2012, Judge Zainey again denied class certification because not all of the questions of law or fact common to the class members predominated over any questions affecting only individual members. Because claims under the TVPA necessarily involve the victim's perspective, the Court concluded these claims were not proper for certification. A determination on forced labor requires the jury to consider an individual's consent or lack thereof and whether the victim was coerced subjectively to provide labor based on the defendant's threats. Even if there were characteristics common to the class, such as immigration status or payment of exorbitant fees, the Court found that these characteristics did not substitute for the subjective aspects of why each plaintiff would stay at Signal. Additionally, part of the harms claimed were financial and reputational harms -- factors that were uniquely individual in nature.

Plaintiffs' § 1981 claim for discriminatory employment practices on the basis of race, national origin, and immigration status was also found to be inappropriate for class status. Plaintiffs acknowledged they would need to forgo emotional distress claims in order to be granted class certification. The Court noted that the recruitment refunds plaintiffs sought were not attributable to the workplace discrimination allegedly carried out by Signal. The Court was also concerned that plaintiffs' willingness to forgo emotional distress recovery threatened the rights of the class members, since the complaint alleged a significant amount of emotional harm. Given that each individual plaintiff in this case had the potential for a large recovery, the Court did not find that class certification would be superior to individual trials.

The Court found that plaintiffs' RICO claims were inappropriate for certification because the predicate acts that need to be proven require individualized proof. Plaintiffs would also be unable to show causation for their RICO injuries without resorting to individual proof of reliance. Finally, the Court found plaintiffs' KKK Act claims to be inappropriate for certification because the kind of coercion needed to show a violation of the 13th Amendment -- physical or legal coercion that requires the victim to work by law -- was not at issue in this case.

Once class certification was denied, it was decided that this case would proceed with the twelve named plaintiffs. Judge Zainey determined the initial trial would consist of five of the named plaintiffs; the plaintiffs would select three and Signal would select two.

On July 12, 2014, the U.S. Judicial Panel on Multidistrict Litigation denied Signal's motion to transfer all of the cases pending against it to the Eastern District of Louisiana.

On Aug. 5, 2014, plaintiffs filed their final Sixth Amended Complaint.

On Aug. 12, 2014, District Judge Susie Morgan denied Signal's motion to dismiss plaintiffs' claims under the FLSA for recruitment fees. The Court granted Signal's motion to dismiss claims for inbound travel and visa expenses under the FLSA, because plaintiffs did not plead that these expenses were primarily for the benefit of Signal.

On Oct. 14, 2014, Judge Morgan denied Signal's motion for interlocutory appeal of the Court's prohibition of discovery on plaintiffs' post-Signal information including immigration status.

On Jan. 6, 2015, Judge Morgan determined that the law of India would govern the claims of fraud and negligent misrepresentation, while the law of Mississippi would govern the claims of breach of contract, quasi-contract, and agency.

On Jan. 27, 2015, Judge Morgan issued an order pertaining to briefing she had required the parties to submit on issues of law under the TVPA. She found that punitive damages were allowed under the TVPA, while the affirmative defense of in pari delicto (arguing that two parties are equally at fault) is not, as it is squarely at odds with the policy behind the TVPA. She also found that psychological and reputational harm were included in the definition of "serious harm" under the TVPA.

By the time of trial, the only remaining defendants were Signal, Burnett, and Dewan. (Co-defendants J&M, Rao, and Pol were all in bankruptcy proceedings, which stayed judgment against them.)

A 24-day jury trial concluded on Feb. 18, 2015; the jury awarded plaintiffs $14,100,000 in damages. The jury decided in favor of plaintiffs regarding their claims of discriminatory terms and conditions of employment, retaliation, intentional infliction of emotional distress, and false imprisonment, and in favor of the defendants regarding RICO and fraud (these being subsumed under the other claims).

The jury decided the breach of contract claim in favor of Burnett and Dewan but awarded damages to plaintiffs against Signal, Burnett Law Offices, and Dewan Consultants. The TVPA claim was divided similarly, with the jury finding in favor of Burnett and Dewan but against Signal, Burnett Law Offices, and Dewan Consultants. The TVPA findings for Burnett and Dewan were reversed by the Court on Sept. 9, 2015.

Post-trial, the parties contested whether the Court should enter a final judgment for the five trial plaintiffs despite the pending claims from the other seven plaintiffs, or whether the second trial should take place first. On Mar. 20, 2015, the Court entered final judgment, reasoning that the plaintiffs had “been waiting since the George W. Bush Administration for their day in court,” and that there was no “just reason” to delay a final determination.

On Aug. 14, 2015, plaintiffs filed a motion to receive attorneys’ fees (for over $5 million). After the District Court enjoined the Burnett defendants from transferring money out of their bank account, on Aug. 28, Dewan and Burnett both appealed plaintiffs' motion on Sept. 23, 2015. However, parties appear to have settled the matter, including dismissing the appeal. We do not have information on the terms of this specific settlement of attorneys' fees.

In Dec. 2015, in the related EEOC case, the EEOC announced that the parties had reached a settlement for all cases, approved by the bankruptcy court. Signal would pay $5 million to 476 guestworkers through a claims process. All aggrieved individuals included in the litigation could receive relief in spite of the bankruptcy proceedings. Signal's CEO also issued an apology for its conduct.

On Apr. 18, 2017 in David, the District Court entered a sealed stipulated judgment as to Dewan. The same day, the Court dismissed Burnett as a defendant, with prejudice. On Apr. 26 the Court also dismissed Dewan as a defendant, without prejudice. The court ruled plaintiffs had the right to reopen the action against Dewan if the settlement was not carried out by Aug. 1, 2018. On Aug. 2, 2018 the plaintiffs and defendants submitted a Joint Motion to extend the time period Dewan had to complete the settlement until October 1, 2018, with the Court retaining jurisdiction to enforce the settlement agreement against Dewan.

As of the writing of this summary (on November 30, 2019), there has been no indication that the defendants completed the settlement. It is unclear whether litigation remains ongoing for the remaining seven plaintiffs, as a trial date has yet to be determined; or whether their claims have been settled.

The many related cases are listed below.

Summary Authors

Anna Dimon (4/9/2015)

Allison Hight (1/11/2016)

Ava Morgenstern (11/30/2017)

Anna Brito (10/17/2018)

Caitlin Kierum (11/30/2019)

Related Cases

Equal Employment Opportunity Commission v. Signal International, LLC, Eastern District of Louisiana (2011)

Achari v. Signal International, LLC, Eastern District of Louisiana (2013)

Joseph v. Signal International, LLC, Eastern District of Texas (2013)

Samuel v. Signal International, LLC, Eastern District of Texas (2013)

Marimuthu v. Signal International, LLC, Eastern District of Texas (2013)

Chakkiyattil v. Signal International, LLC, Eastern District of Louisiana (2013)

Krishnakutty v. Signal International, LLC, Eastern District of Louisiana (2013)

Meganathan v. Signal International, LLC, Eastern District of Texas (2013)

Kambala v. Signal International, LLC, Eastern District of Texas (2013)

Devassy v. Signal International, LLC, Eastern District of Louisiana (2013)

Singh v. Signal International, LLC, Eastern District of Louisiana (2013)

People

For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/4269237/parties/david-v-signal-international-llc/


Judge(s)

Knowles, Daniel E. III (Louisiana)

Morgan, Susie [Sue, Donna] (Louisiana)

Zainey, Jay C. (Louisiana)

Attorneys(s) for Plaintiff

Ahmed, Sameer (New York)

Bauer, Mary C. (Georgia)

Bhatnagar, Chandra S. (New York)

Bjarnson, Joseph (New York)

Bouhabib, Melia Amal (New York)

Davitt, Vincent (California)

Dees, Morris S. Jr. (Alabama)

Judge(s)

Knowles, Daniel E. III (Louisiana)

Morgan, Susie [Sue, Donna] (Louisiana)

Zainey, Jay C. (Louisiana)

Attorneys(s) for Plaintiff

Ahmed, Sameer (New York)

Bauer, Mary C. (Georgia)

Bhatnagar, Chandra S. (New York)

Bjarnson, Joseph (New York)

Bouhabib, Melia Amal (New York)

Davitt, Vincent (California)

Dees, Morris S. Jr. (Alabama)

Ferris, Ashleigh (Georgia)

Gorman, Sean (Texas)

Graunke, Kristi L. (Georgia)

Hangartner, Erin Casey (Louisiana)

Howard, Alan B. (New York)

Jain, Anita (California)

Kim, Dahsong (New York)

Lin, Shirley (New York)

Nair, Anjali (Alabama)

Rosenbaum, Jennifer J. (Alabama)

Sandler, Hugh (New York)

Sheth, Tushar J. (New York)

Stewart, Jennifer M. (New York)

Suriyopas, Ivy O. (New York)

Suzuki, Chieni D. (New York)

Tsu, Naomi Ruth (Georgia)

Warf, Samuel Justin (Texas)

Washington, Tracie L. (Louisiana)

Werner, Daniel (Georgia)

Wynne, Robert P. (Texas)

Attorneys(s) for Defendant

Adams, Glenn B. (Louisiana)

Aiyegbusi, Denia Sylve (Louisiana)

Alexis, Ralph R. III (Louisiana)

Binion, Mack B. (Alabama)

Bollman, Patricia Anne F. (Louisiana)

Buckley, Elliot Ross Jr. (Louisiana)

Buras, Daniel Edwin Jr. (Louisiana)

Cerniglia, Timothy W. (Louisiana)

Cornblatt, James L. (Louisiana)

Curenton, James G. Jr. (Alabama)

Davis, Lauren Masur (Louisiana)

Douglas, Donald C. Jr. (Louisiana)

Gianna, Dominic Joseph (Louisiana)

Gipson, Kevin Kennedy (Louisiana)

Hardin, Emily Stevens (Louisiana)

Harowski, Christie C. (Louisiana)

Hasenkampf, Mitchell P. (Louisiana)

Johnson, Patrick Jr. (Louisiana)

Keller, Robert Louis (Louisiana)

Kupperman, Stephen H. (Louisiana)

Madere, Michael J. (Louisiana)

McMullan, Johanna Malbrough (Mississippi)

Miles, Stephen L. (Louisiana)

Miller, Margaret M. (Alabama)

Mirabile, Paul John (Louisiana)

Person, John Christopher (Louisiana)

Rabbani, Elham (Louisiana)

Roux, Brian C. (Louisiana)

Rydberg, Lance R. (Louisiana)

Shapiro, Stephen H. (Louisiana)

Ungar, Hal D. (Louisiana)

Weinberger, Alan Dean (Louisiana)

Whitehead, Michael E. (Mississippi)

Wyatt, Brent C. (Louisiana)

Documents in the Clearinghouse

Document

Docket [PACER]

David v. Signal International LLC

Aug. 2, 2018 Docket
1

Complaint

David v. Signal International LLC

March 7, 2008 Complaint
45

RICO Case Statement

David v. Signal International LLC

April 28, 2008 Pleading / Motion / Brief
156

Order and Reasons

David v. Signal International LLC

2008 WL 4266214

Sept. 11, 2008 Order/Opinion
367

Order and Reasons

257 F.R.D. 114

April 2, 2009 Order/Opinion
617

Order (re: Rao's Attorney-Client Privilege)

2009 WL 5215326

Dec. 28, 2009 Order/Opinion
747

Order

2010 WL 2723180

July 6, 2010 Order/Opinion
797

Consent Protective Order

July 29, 2010 Order/Opinion
854

Order (re: Signal’s Motion to Compel Production of T-Visa Applications)

735 F.Supp.2d 440

Aug. 26, 2010 Order/Opinion
912

Order

2010 WL 4667972

Nov. 5, 2010 Order/Opinion

Resources

Title Description External URL

David, et al. v. Signal International, LLC, et al.

American Civil Liberties Union (ACLU)

Hundreds of workers trafficked to the U.S. from India to work in shipyards after Hurricane Katrina were lured here with dishonest assurances of becoming lawful permanent U.S. residents. In February 2… May 29, 2013 https://www.aclu.org/cases/david-et-al-v-signal-international-llc-et-al

Signal International Lawsuits

Southern Poverty Law Center (SPLC)

The SPLC filed suit on behalf of guest workers from India who were defrauded and exploited in a labor trafficking scheme engineered by a Gulf Coast marine services company, an immigration lawyer and … Feb. 28, 2015 https://www.splcenter.org/seeking-justice/case-docket/signal-international-lawsuits

Settlements End Multiple H-2B Human-Trafficking Suits

Knaub, Kelly

Law360, New York (April 7, 2017, 4:48 PM EDT) -- Foreign workers who sued Signal International over alleged human trafficking have reached settlements with two law firms and an attorney who were also… April 7, 2017 https://www.law360.com/articles/910826/settlements-end-multiple-h-2b-human-trafficking-suits

Docket

See docket on RECAP: https://www.courtlistener.com/docket/4269237/david-v-signal-international-llc/

Last updated May 12, 2022, 8 p.m.

ECF Number Description Date Link
1

COMPLAINT against all defendants (Filing fee $ 350.) filed by all plaintiffs. (Attachments: # 1 Complaint (Cont)# 2 Exhibit 1# 3 Civil Cover Sheet)(gbw, ) (Entered: 03/10/2008)

1 Complaint (Cont)

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2 Exhibit 1

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3 Civil Cover Sheet

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March 7, 2008 RECAP
2

Summons Issued as to Signal InternationaL LLC, Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C., Indo-Ameri Soft L.L.C., Kurella Rao, J & M Associates, Inc. of Mississippi, Global Resources, Inc., Michael Pol, Sachin Dewan, Dewan Consultants Pvt. Ltd.. (gbw, ) (Entered: 03/10/2008)

March 7, 2008 PACER
7

EXPARTE/CONSENT MOTION to Appear Pro Hac Vice as to Kristi L. Graunke (Filing fee $5. PAID) by all plaintiffs. (gbw, ) (Entered: 03/17/2008)

March 7, 2008 PACER
9

EXPARTE/CONSENT MOTION to Appear Pro Hac Vice as to Jennifer Rosenbaum (Filing fee $5. PAID) by all plaintiffs. (gbw, ) (Entered: 03/17/2008)

March 7, 2008 PACER
12

EXPARTE/CONSENT MOTION to Appear Pro Hac Vice as to Morris Dees (Filing fee $5. PAID) by all plaintiffs. (gbw, ) (Entered: 03/18/2008)

March 7, 2008 PACER
14

EXPARTE/CONSENT MOTION to Appear Pro Hac Vice as to Tushar J. Sheth (Filing fee $5. PAID) by all plaintiffs. (gbw, ) (Entered: 03/18/2008)

March 7, 2008 PACER
15

EXPARTE/CONSENT MOTION to Appear Pro Hac Vice as to Daniel Werner (Filing fee $5. PAID) by all plaintiffs. (gbw, ) (Entered: 03/18/2008)

March 7, 2008 PACER
3

RICO STANDING ORDER. By Clerk.(jrc, ) (Entered: 03/10/2008)

March 10, 2008 PACER
4

SUMMONS Returned Executed; Law Offices of Malvern C. Burnett, A.P.C. served on 3/12/2008. (gbw, ) (Entered: 03/14/2008)

March 13, 2008 PACER
5

SUMMONS Returned Executed; Malvern C. Burnett served on 3/12/2008. (gbw, ) (Entered: 03/14/2008)

March 13, 2008 PACER
6

SUMMONS Returned Executed; Gulf Coast Immigration Law Center, L.L.C. served on 3/12/2008. (gbw, ) (Entered: 03/14/2008)

March 13, 2008 PACER
8

ORDER granting 7 Motion to Appear Pro Hac Vice as to Kristi L. Graunke.. Signed by Judge Jay C. Zainey on 3/13/08. (gbw, ) (Entered: 03/17/2008)

March 13, 2008 PACER
10

ORDER granting 9 Motion to Appear Pro Hac Vice as to Jennifer Rosenbaum.. Signed by Judge Jay C. Zainey on 3/13/08. (gbw, ) (Entered: 03/17/2008)

March 13, 2008 PACER
18

ORDER granting 14 Motion to Appear Pro Hac Vice as to Tushar J. Sheth.. Signed by Judge Jay C. Zainey on 3/13/08. (gbw, ) (Entered: 03/20/2008)

March 13, 2008 PACER
19

ORDER granting 15 Motion to Appear Pro Hac Vice as to Daniel Werner.. Signed by Judge Jay C. Zainey on 3/13/08. (gbw, ) (Entered: 03/20/2008)

March 13, 2008 PACER
17

ORDER granting 12 Motion to Appear Pro Hac Vice as to Morris S. Dees.. Signed by Judge Jay C. Zainey on 3/13/08. (gbw, ) (Entered: 03/20/2008)

March 14, 2008 PACER
11

SUMMONS Returned Executed; Signal InternationaL LLC served on 3/10/2008. (gbw, ) (Entered: 03/18/2008)

March 17, 2008 PACER
13

EXPARTE/CONSENT MOTION to Appear Pro Hac Vice as to Mary Bauer (Filing fee $5. PAID) by all plaintiffs. (gbw, ) Additional attachment(s) added on 3/18/2008 (gbw, ). Additional attachment(s) added on 3/18/2008 (gbw, ). (Entered: 03/18/2008)

1 Declaration

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2 Certificate

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March 17, 2008 PACER
16

ORDER granting 13 Motion to Appear Pro Hac Vice as to Mary C. Bauer.. Signed by Judge Jay C. Zainey on 3/17/08. (gbw, ) (Entered: 03/20/2008)

March 18, 2008 PACER
20

EXPARTE/CONSENT First MOTION for Extension of Time to Answer re 1 Complaint by Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C.. (Attachments: # 1 Proposed Order)(Alexis, Ralph) (Entered: 03/20/2008)

1 Proposed Order

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March 20, 2008 PACER
21

EXPARTE/CONSENT First MOTION for Extension of Time to Answer re 1 Complaint of plaintiffs by Signal InternationaL LLC. (Attachments: # 1 Proposed Order)(Hangartner, Erin) (Entered: 03/24/2008)

1 Proposed Order

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March 24, 2008 PACER
22

ORDER granting 21 Motion for Extension of Time to Answer. Signed by Judge Jay C. Zainey on 3/25/08. (ala, ) (Entered: 03/26/2008)

March 26, 2008 PACER
23

ORDER granting 20 Motion for Extension of Time to Answer as to Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C. and Law Offices of Malvern C. Burnett, A.P.C. answer due 4/21/2008. Signed by Judge Jay C. Zainey on 3/26/08. (ala, ) (Entered: 03/26/2008)

March 26, 2008 PACER
24

EXPARTE/CONSENT MOTION for Extension of Time to File RICO Case Statement by Kurian David. (Attachments: # 1 Proposed Order)(Graunke, Kristi) (Entered: 03/26/2008)

1 Proposed Order

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March 26, 2008 PACER
25

ORDER granting 24 Motion for Extension of Time to File RICO Case Statement as set forth in document. Signed by Judge Jay C. Zainey on 3/28/08. (ecm, ) (Entered: 03/31/2008)

March 31, 2008 PACER
26

EXPARTE/CONSENT Second MOTION for Extension of Time to Answer by Signal International LLC. (Attachments: # 1 Proposed Order)(Douglas, Donald) (Entered: 04/11/2008)

1 Proposed Order

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April 11, 2008 PACER
27

ORDER granting 26 Motion for Extension of Time to Answer. Signed by Judge Jay C. Zainey on 4/11/08. (ala, ) (Entered: 04/14/2008)

April 14, 2008 PACER
28

EXPARTE MOTION for Extension of Time to Answer by Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C.. (Attachments: # 1 Proposed Order)(Alexis, Ralph) Modified on 4/15/2008 (gbw, ). (Entered: 04/14/2008)

1 Proposed Order

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April 14, 2008 PACER
29

EXPARTE/CONSENT MOTION for Extension of Time to Answer Complaint by Global Resources, Inc., Michael Pol. (Attachments: # 1 Proposed Order)(Harowski, Christy) Modified text on 4/17/2008 (gbw, ). (Entered: 04/16/2008)

1 Proposed Order

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April 16, 2008 PACER
30

ORDER granting 28 Motion for Extension of Time to Answer re 1 Complaint as to Malvern C. Burnett answer due 5/11/2008; Gulf Coast Immigration Law Center, L.L.C. answer due 5/11/2008; Law Offices of Malvern C. Burnett, A.P.C. answer due 5/11/2008.. Signed by Judge Jay C. Zainey on 4/15/08. (gbw, ) (Entered: 04/16/2008)

April 16, 2008 PACER
31

Correction of Docket Entry by Clerk re 29 MOTION for Extension of Time to File Response/Reply to Complaint. Filing attorney selected incorrect event. Correct event is 'MOTION for extension of time to answer' and link to complaint. Clerk took corrective action by either re-docketing the event or changing the event. (gbw, ) (Entered: 04/17/2008)

April 17, 2008 PACER
32

ORDER granting 29 Motion for Extension of Time to Answer re 1 Complaint. Answer due 5/14/08. Signed by Judge Jay C. Zainey on 4/16/08. (gbw, ) (Entered: 04/17/2008)

April 17, 2008 PACER
33

SUMMONS Returned Executed; Global Resources, Inc. served on 4/4/2008, answer due 4/24/2008. (Graunke, Kristi) (Entered: 04/18/2008)

April 18, 2008 PACER
34

EXPARTE/CONSENT Second MOTION for Extension of Time to File RICO Case Statement by Kurian David. (Attachments: # 1 Proposed Order)(Graunke, Kristi) (Entered: 04/18/2008)

1 Proposed Order

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April 18, 2008 PACER
35

RESPONSE/MEMORANDUM in Opposition filed by Signal International LLC re 34 Second MOTION for Extension of Time to File RICO Case Statement. (Weinberger, Alan) (Entered: 04/18/2008)

April 18, 2008 PACER
36

EXPARTE MOTION for Leave to File Reply Memorandum by Kurian David. (Attachments: # 1 Proposed Order # 2 Proposed Pleading Reply Memorandum)(Graunke, Kristi) Modified on 4/21/2008 (gbw, ). (Entered: 04/18/2008)

1 Proposed Order

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2 Proposed Pleading Reply Memorandum

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April 18, 2008 PACER
37

Correction of Docket Entry by Clerk re 36 MOTION for Leave to File Reply Memorandum. Filing attorney should have changed 'N' to 'Y' at the question 'Is this an Exparte/Consent Motion Y/N?' before clicking the Next button. Clerk modified docket text to reflect 'Exparte (gbw, ) (Entered: 04/21/2008)

April 21, 2008 PACER
38

ORDER granting 36 Motion for Leave to File reply memo in support of second motion for extension of time to file RICO case statement. Signed by Judge Jay C. Zainey on 4/21/08. (gbw, ) (Entered: 04/23/2008)

April 23, 2008 PACER
39

RESPONSE/MEMORANDUM in Support filed by all plaintiffs re 34 Second MOTION for Extension of Time to File RICO Case Statement. (gbw, ) (Entered: 04/23/2008)

April 23, 2008 PACER
40

ORDER granting 34 Motion for Extension of Time until 4/24/08 to File RICO case statement.. Signed by Judge Jay C. Zainey on 4/22/08. (gbw, ) (Entered: 04/24/2008)

April 23, 2008 PACER
41

EXPARTE/CONSENT MOTION to Amend/Correct Extension Order by Kurian David. (Attachments: # 1 Proposed Order)(Graunke, Kristi) Modified on 4/25/2008 (gec, ). (Entered: 04/24/2008)

1 Proposed Order

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April 24, 2008 PACER
42

Correction of Docket Entry by Clerk re 41 MOTION to Amend/Correct Extension Order. Filing attorney should have changed 'N' to 'Y' at the question 'Is this an Exparte/Consent Motion Y/N?' before clicking the Next button. Clerk modified docket text. (gec, ) (Entered: 04/25/2008)

April 25, 2008 PACER
43

ORDER granting 41 Motion to Amend/Correct; Plaintiff's RICO Case Statement is due 4/28/08. Signed by Judge Jay C. Zainey on 4/24/08. (jrc, ) (Entered: 04/25/2008)

April 25, 2008 PACER
44

**DEFICIENT** First AMENDED COMPLAINT against all defendants filed by Kurian David. (Attachments: # 1 Supplement part II of First Amended Complaint# 2 Exhibit 1, part I# 3 Exhibit 1, part II of III# 4 Exhibit 1 part III of III# 5 Exhibit 2)(Graunke, Kristi) Modified on 4/29/2008 (gec, ). (Entered: 04/28/2008)

1 Supplement part II of First Amended Complaint

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2 Exhibit 1, part I

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3 Exhibit 1, part II of III

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4 Exhibit 1 part III of III

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5 Exhibit 2

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April 28, 2008 PACER
45

RICO Case Statement by all plaintiffs. (Attachments: # 1 Exhibit Fraud Chart Part I of 3# 2 Exhibit Fraud Chart, Part 2 of 3# 3 Exhibit Fraud Chart Part 3 of 3)(Rosenbaum, Jennifer) (Entered: 04/28/2008)

1 Exhibit Fraud Chart Part I of 3

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2 Exhibit Fraud Chart, Part 2 of 3

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3 Exhibit Fraud Chart Part 3 of 3

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April 28, 2008 PACER
46

Correction of Docket Entry by Clerk re 45 RICO Case Statement. Document does not reflect Magistrate Judge. All future pleadings must reflect Magistrate Judge Daniel E. Knowles, III (3). (gec, ) (Entered: 04/29/2008)

April 29, 2008 PACER
47

First AMENDED COMPLAINT against all defendants filed by Kurian David. (Attachments: # 1 Exhibit 1, part I# 2 Exhibit 1, part II of III# 3 Exhibit 1, part III of III# 4 Exhibit 2)(Graunke, Kristi) (Entered: 04/29/2008)

1 Exhibit 1, part I

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2 Exhibit 1, part II of III

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3 Exhibit 1, part III of III

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4 Exhibit 2

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April 29, 2008 RECAP
48

STIPULATION by all plaintiffs. (Attachments: # 1 Certificate of Service)(Rosenbaum, Jennifer) (Entered: 04/30/2008)

1 Certificate of Service

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April 30, 2008 PACER
49

AFFIDAVIT of Service by Christy Harowski of Summons and Complaint served on Michael Pol on April 30, 2008. (Attachments: # 1 Affidavit Affirmation of Service)(Graunke, Kristi) Modified on 5/5/2008 (gbw, ). (Entered: 05/02/2008)

May 2, 2008 PACER
52

SUMMONS Returned Executed; Michael Pol served on 4/30/2008. (Attachments: # 1 Affirmation)(gbw, ) Modified on 5/5/2008 (gbw, ). (Entered: 05/05/2008)

May 2, 2008 PACER
50

NOTICE by all plaintiffs FLSA Consents to Sue. (Attachments: # 1 Exhibit 1)(Graunke, Kristi) (Entered: 05/03/2008)

1 Exhibit 1

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May 3, 2008 PACER
51

Correction of Docket Entry by Clerk re 49 Affidavit of Service. Filing attorney selected incorrect event. Correct event is 'Summons returned executed'. Clerk took corrective action by either re-docketing the event or changing the event. (gbw, ) (Entered: 05/05/2008)

May 5, 2008 PACER
53

DEFICIENT. SUMMONS Returned Executed; Indo-Ameri Soft L.L.C. served on 5/5/2008, answer due 5/27/2008. (Graunke, Kristi) Modified on 5/8/2008 (gbw, ). (Entered: 05/07/2008)

May 7, 2008 PACER
54

DEFICIENT. SUMMONS Returned Executed; Kurella Rao served on 5/5/2008, answer due 5/27/2008. (Graunke, Kristi) Modified on 5/8/2008 (gbw, ). (Entered: 05/07/2008)

May 7, 2008 PACER
55

SUMMONS Returned Executed; Kurella Rao served on 5/5/08. (Graunke, Kristi) Modified on 5/9/2008 (gbw, ). (Entered: 05/08/2008)

May 8, 2008 PACER
56

SUMMONS Returned Executed; (Graunke, Kristi); Indo-Amer Soft LLC served on 5/5/08. Modified on 5/9/2008 (gbw, ). (Entered: 05/08/2008)

May 8, 2008 PACER
57

EXPARTE/CONSENT Third MOTION for Extension of Time to Answer by Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C.. (Attachments: # 1 Proposed Order)(Alexis, Ralph) (Entered: 05/08/2008)

1 Proposed Order

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May 8, 2008 PACER
58

Correction of Docket Entry by Clerk re 55 Summons Returned Executed. Filing attorney did not select Kurella Rao as a party served. Clerk added party served. (gbw, ) (Entered: 05/09/2008)

May 9, 2008 PACER
59

Correction of Docket Entry by Clerk re 56 Summons Returned Executed. Filing attorney did not select Indo-Amer Soft LLC as the party served. Clerk added the party served. (Entered: 05/09/2008)

May 9, 2008 PACER
60

ANSWER to Amended Complaint, THIRD PARTY COMPLAINT against Zito Companies, L.L.C., CROSSCLAIM against Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C., Indo-Ameri Soft L.L.C., Kurella Rao, J & M Associates, Inc. of Mississippi, Global Resources, Inc., Michael Pol, Sachin Dewan, Dewan Consultants Pvt. Ltd. by Signal International LLC.(Hangartner, Erin) Exhibit added on 5/12/2008 (gbw, ). Modified on 5/12/2008 (gbw, ). Modified on 5/12/2008 (gbw, ). (Entered: 05/09/2008)

1 Exhibit

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May 9, 2008 PACER
61

SUMMONS Returned Executed; J & M Associates, Inc. of Mississippi served on 5/6/2008, answer due 5/27/2008. (Graunke, Kristi) (Entered: 05/11/2008)

May 11, 2008 PACER
62

Correction of Docket Entry by Clerk re 60 Answer to Amended Complaint, Third Party Complaint, Crossclaim. Exhibit was subsequently provided to Clerk and has now been attached to the document. (gbw, ) (Entered: 05/12/2008)

May 12, 2008 PACER
63

Third-Party Summons Issued as to Zito Companies, L.L.C.. (gbw, ) (Entered: 05/12/2008)

May 12, 2008 PACER
64

ORDER granting 57 Motion for Extension of Time to Answer re 1 Complaint. Answer due 5/20/08. Signed by Judge Jay C. Zainey on 5/9/08. (gbw, ) (Entered: 05/12/2008)

May 12, 2008 PACER
65

SUMMONS Returned Executed; Zito Companies, L.L.C. served on 5/14/2008, answer due 6/3/2008. (Hangartner, Erin) (Entered: 05/14/2008)

May 14, 2008 PACER
66

MOTION to Dismiss for Lack of Personal Jurisdiction, Improper Venue, and Failure to Plead Fraud with Particularity by Global Resources, Inc., Michael Pol. Motion Hearing set for 6/11/2008 09:00 AM before Judge Jay C. Zainey. (Attachments: # 1 Memorandum in Support, # 2 Affidavit, # 3 Notice of Hearing)(Kupperman, Stephen) (Entered: 05/19/2008)

1 Memorandum in Support

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2 Affidavit

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3 Notice of Hearing

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May 19, 2008 PACER
67

EXPARTE/CONSENT Fourth MOTION for Extension of Time to Answer by Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C.. (Attachments: # 1 Proposed Order)(Alexis, Ralph) (Entered: 05/20/2008)

1 Proposed Order

View on PACER

May 20, 2008 PACER
68

ORDER granting 67 Motion for Extension of Time to Answer. Signed by Judge Jay C. Zainey. (jrc, ) (Entered: 05/20/2008)

May 20, 2008 PACER
69

EXPARTE/CONSENT First MOTION for Extension of Time to Answer by J & M Associates, Inc. of Mississippi. (Attachments: # 1 Proposed Order)(McMullan, Johanna) (Entered: 05/21/2008)

1 Proposed Order

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May 21, 2008 PACER
70

MOTION to Dismiss by Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C.. Motion Hearing set for 6/25/2008 09:00 AM before Judge Jay C. Zainey. (Attachments: # 1 Memorandum in Support, # 2 Notice of Hearing)(Alexis, Ralph) (Entered: 05/21/2008)

1 Memorandum in Support

View on RECAP

2 Notice of Hearing

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May 21, 2008 PACER
71

Request/Statement of Oral Argument by Malvern C. Burnett regarding 70 MOTION to Dismiss (Alexis, Ralph) Corrected Image added on 5/22/2008. Modified on 5/22/2008 (gbw, ). (Entered: 05/21/2008)

May 21, 2008 PACER
72

Correction of Docket Entry by Clerk re 71 Request/Statement of Oral Argument. Image of document was submitted sideways. All documents must be in PDF format before e-filing. Clerk took corrective action. (gbw, ) (Entered: 05/22/2008)

May 22, 2008 PACER
73

DEFICIENT. MOTION for Extension of Time to File Class Certification Motion by Kurian David. Motion Hearing set for 6/11/2008 before Judge Jay C. Zainey. (Attachments: # 1 Proposed Order, # 2 Notice of Hearing)(Graunke, Kristi) Modified on 5/23/2008 (gbw, ). (Entered: 05/22/2008)

1 Proposed Order

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2 Notice of Hearing

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May 22, 2008 PACER
74

ORDER granting 69 Motion for Extension of Time to Answer re 1 Complaint. Answer due 6/16/08. Signed by Judge Jay C. Zainey on 5/23/08. (gbw, ) (Entered: 05/23/2008)

May 23, 2008 PACER
75

EXPARTE/CONSENT MOTION to Continue Hearing on Motions to Dismiss to July 9, 2008 by Kurian David. (Attachments: # 1 Proposed Order)(Graunke, Kristi) (Entered: 05/24/2008)

1 Proposed Order

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May 24, 2008 PACER
76

MOTION for Extension of Time to File Class Certification Motion by Kurian David. Motion Hearing set for 6/11/2008 09:00 AM before Judge Jay C. Zainey. (Attachments: # 1 Memorandum in Support, # 2 Proposed Order, # 3 Notice of Hearing)(Graunke, Kristi) (Entered: 05/24/2008)

1 Memorandum in Support

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2 Proposed Order

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3 Notice of Hearing

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May 24, 2008 PACER
77

ORDER Resetting Hearing on 66 MOTION to Dismiss for Lack of Personal Jurisdiction, Improper Venue, and Failure to Plead Fraud with Particularity, 70 MOTION to Dismiss; Motion Hearings set for 7/9/2008 before Judge Jay C. Zainey. Signed by Judge Jay C. Zainey.(jrc, ) (Entered: 05/27/2008)

May 27, 2008 PACER
78

EXPARTE/CONSENT First MOTION for Extension of Time to Answer re 60 Crossclaim by Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C.. (Attachments: # 1 Proposed Order)(Alexis, Ralph) Modified on 6/2/2008 (gbw, ). (Entered: 05/30/2008)

1 Proposed Order

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May 30, 2008 PACER
79

MOTION to Dismiss Third Party Complaint by Zito Companies, L.L.C.. Motion Hearing set for 6/25/2008 09:00 AM before Judge Jay C. Zainey. (Attachments: # 1 Memorandum in Support, # 2 Notice of Hearing)(Person, John) (Entered: 06/02/2008)

1 Memorandum in Support

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2 Notice of Hearing

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June 2, 2008 PACER
80

ORDER granting 78 Motion for Extension of Time to Answer. Signed by Judge Jay C. Zainey. (jrc, ) (Entered: 06/02/2008)

June 2, 2008 PACER
81

EXPARTE/CONSENT MOTION to Appear Pro Hac Vice Michael E. Whitehead (Filing fee $5. PAID) by J & M Associates, Inc. of Mississippi. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Affidavit Exhibit C, # 4 Proposed Order)(McMullan, Johanna) Modified on 6/4/2008 (gbw, ). Modified on 6/10/2008 (gec, ). (Entered: 06/03/2008)

1 Exhibit A

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2 Exhibit B

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3 Affidavit Exhibit C

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4 Proposed Order

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June 3, 2008 PACER
82

NOTICE of Change of Address by Kristi L. Graunke on behalf of all plaintiffs. (Graunke, Kristi) (Entered: 06/05/2008)

June 5, 2008 PACER
83

ANSWER to 1 Complaint, 47 Amended Complaint by Kurella Rao, Indo-Ameri Soft L.L.C..(Gipson, Kevin) (Additional attachment(s) added on 6/10/2008: # 1 Certificate of Service) (gec, ). Modified on 6/10/2008 (gec, ). (Entered: 06/09/2008)

1 Certificate of Service

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June 9, 2008 PACER
84

**ERROR: FILED AS A SEPARATE DOCUMENT; NOW ATTACHED TO REC. DOC. 83** CERTIFICATE OF SERVICE by Indo-Ameri Soft L.L.C., Kurella Rao re 47 Amended Complaint, 44 Amended Complaint, 1 Complaint. (Gipson, Kevin) Modified on 6/10/2008 (gec, ). (Entered: 06/09/2008)

June 9, 2008 PACER
88

ORDER granting 81 Motion to Appear Pro Hac Vice for Attorney Michael E. Whitehead for J & M Associates, Inc. of Mississippi. Signed by Judge Jay C. Zainey on 6/9/08. (gec, ) (Entered: 06/10/2008)

June 9, 2008 PACER
89

ORDER granting unopposed 76 Motion for Extension of Time to File Motion for Class Certification. Signed by Judge Jay C. Zainey on 6/9/08. (gec, ) (Entered: 06/10/2008)

June 9, 2008 PACER
85

RESPONSE/MEMORANDUM in Opposition filed by Signal International LLC re 79 MOTION to Dismiss Third Party Complaint. (Douglas, Donald) (Entered: 06/10/2008)

June 10, 2008 RECAP
86

Correction of Docket Entry by Clerk re 83 Answer to Complaint, Answer to Amended Complaint. Filing attorney did not select Indo-Ameri Soft L.L.C. as a filer. Clerk added filer. Filing attorney incorrectly linked document to deficient document (rec. doc. 44). Clerk took corrective action. (gec, ) (Entered: 06/10/2008)

June 10, 2008 PACER
87

Correction of Docket Entry by Clerk re 84 Certificate of Service. Document was incorrectly filed as a separate document instead of an attachment to document #83. Clerk took corrective action. (gec, ) (Entered: 06/10/2008)

June 10, 2008 PACER
90

STIPULATION by all plaintiffs to Rule 34 inspection (Graunke, Kristi) (Entered: 06/13/2008)

June 13, 2008 PACER
91

EXPARTE/CONSENT MOTION for Leave to File Reply Brief by Zito Companies, L.L.C.. (Attachments: # 1 Proposed Order, # 2 Supplement Reply Brief, # 3 Affidavit)(Person, John) (Entered: 06/13/2008)

1 Proposed Order

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2 Supplement Reply Brief

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3 Affidavit

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June 13, 2008 PACER
92

DEFICIENT. MOTION to Dismiss and Alternatively,, MOTION to Transfer Case by J & M Associates, Inc. of Mississippi. Motion Hearing set for 7/9/2008 09:00 AM before Judge Jay C. Zainey. (Attachments: # 1 Memorandum in Support)(McMullan, Johanna) Modified on 6/17/2008 (gbw, ). (Entered: 06/16/2008)

1 Memorandum in Support

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June 16, 2008 PACER
93

ANSWER to 60 Crossclaim by J & M Associates, Inc. of Mississippi.(McMullan, Johanna) Modified on 6/17/2008 (gbw, ). (Entered: 06/16/2008)

June 16, 2008 PACER
94

NOTICE by all plaintiffs Filing FLSA consents to sue. (Attachments: # 1 Consent Forms)(Graunke, Kristi) Modified on 6/17/2008 (gbw, ). (Entered: 06/16/2008)

1 Exhibit 1

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June 16, 2008 PACER
95

DUPLICATE DOCUMENT. NOTICE by all plaintiffs File FLSA consent to sue 6-16-08. (Attachments: # 1 Exhibit 1)(Graunke, Kristi) Modified on 6/17/2008 (gbw, ). (Entered: 06/16/2008)

1 Consent Forms

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June 16, 2008 PACER
96

NOTICE by all plaintiffs filing of FLSA consent to sue. (Attachments: # 1 Consent Form)(Graunke, Kristi) Modified on 6/17/2008 (gbw, ). Modified on 6/17/2008 (gbw, ). (Entered: 06/16/2008)

1 Consent Form

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June 16, 2008 PACER
99

ORDER granting 91 Motion for Leave to File reply memo to motion to dismiss. Signed by Judge Jay C. Zainey on 6/16/08. (gbw, ) (Entered: 06/17/2008)

June 16, 2008 PACER
97

Correction of Docket Entry by Clerk re 95 Notice (Other). This is a duplicate filing of document 94 and 96 and will be noted as such. No further action is necessary. (gbw, ) (Entered: 06/17/2008)

June 17, 2008 PACER
98

MOTION to Dismiss or Alternatively,, MOTION to Transfer Case by J & M Associates, Inc. of Mississippi. Motion Hearing set for 7/9/2008 09:00 AM before Judge Jay C. Zainey. (Attachments: # 1 Memorandum in Support, # 2 Notice of Hearing)(McMullan, Johanna) (Entered: 06/17/2008)

1 Memorandum in Support

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2 Notice of Hearing

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June 17, 2008 PACER
100

REPLY MEMORANDUM filed by Zito Companies, L.L.C. re 79 MOTION to Dismiss Third Party Complaint. (Attachments: # 1 Affidavit)(gbw, ) (Entered: 06/17/2008)

1 Affidavit

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June 17, 2008 PACER

State / Territory: Louisiana

Case Type(s):

Immigration and/or the Border

Special Collection(s):

Signal International Guest Worker Cases

Key Dates

Filing Date: March 7, 2008

Case Ongoing: Yes

Plaintiffs

Plaintiff Description:

500+ Indian guestworkers recruited for work in the United States in exchange for green cards.

Plaintiff Type(s):

Private Plaintiff

Attorney Organizations:

ACLU National (all projects)

Asian American Legal Defense & Educ. Fund (AALDEF)

Southern Poverty Law Center

Public Interest Lawyer: Yes

Filed Pro Se: No

Class Action Sought: Yes

Class Action Outcome: Denied

Defendants

Signal International, Inc. (Pascagoula), Private Entity/Person

Global Resources, Inc. , Private Entity/Person

Michael Pol, None

Dewan Consultants (Substantial Business Contacts with New Orleans, LA), Private Entity/Person

Malvern C. Burnett (New Orleans), None

Law Offices of Malvern C. Burnett (New Orleans), Private Entity/Person

Gulf Coast Immigration Law Center (New Orleans), Private Entity/Person

Indo-Amerisoft, L.L.C. (New Orleans), Private Entity/Person

Kurella Rao (New Orleans), None

J&M Associates of Mississippi, Inc. , Private Entity/Person

Sachin Dewan (Substantial Business Contacts with New Orleans, LA), None

Michael Wilks, None

J & M Marine & Industrial LLC , Private Entity/Person

Case Details

Causes of Action:

42 U.S.C. § 1981

State law

42 U.S.C. § 1985

Racketeer Influenced and Corrupt Organizations Act (RICO), 18 U.S.C. §§ 1961 et seq.

Fair Labor Standards Act (FLSA), 29 U.S.C. §§ 201-219

Trafficking Victims Protection Act (TVPA), 18 U.S.C. § 1589

Special Case Type(s):

Multi-District Litigation (MDL)

Availably Documents:

Trial Court Docket

Complaint (any)

Monetary Relief

Any published opinion

Outcome

Prevailing Party: Plaintiff

Nature of Relief:

Attorneys fees

Damages

Source of Relief:

Settlement

Litigation

Form of Settlement:

Court Approved Settlement or Consent Decree

Amount Defendant Pays: $14,100,000

Issues

General:

Bathing and hygiene

Disparate Treatment

Food service / nutrition / hydration

Housing

Loss or damage to property

Racial segregation

Sanitation / living conditions

Totality of conditions

Discrimination-area:

Discipline

Harassment / Hostile Work Environment

Other Conditions of Employment (including assignment, transfer, hours, working conditions, etc)

Pay / Benefits

Discrimination-basis:

Immigration status

National origin discrimination

Race discrimination

Race:

Asian/Pacific Islander

Type of Facility:

Non-government for profit

Immigration/Border:

Employer sanctions

Employment

Immigration lawyers

Temporary foreign workers program

U.S. citizenship - acquiring

National Origin/Ethnicity:

Indian