Case: Meganathan v. Signal International, LLC

1:13-cv-00497 | U.S. District Court for the Eastern District of Texas

Filed Date: Aug. 7, 2013

Case Ongoing

Clearinghouse coding complete

Case Summary

This case is part of the series of Signal International cases. It is stayed during defendant's bankruptcy and settlement proceedings.On Aug. 7, 2013, four Indian guestworkers filed this lawsuit in the U.S. District Court for the Eastern District of Texas for harm suffered as a result of an allegedly fraudulent and coercive employment recruitment scheme. Plaintiffs filed this suit after District Judge Jay Zainey denied class certification on January 3, 2012 in a related case, David v. Signal Int…

This case is part of the series of Signal International cases. It is stayed during defendant's bankruptcy and settlement proceedings.

On Aug. 7, 2013, four Indian guestworkers filed this lawsuit in the U.S. District Court for the Eastern District of Texas for harm suffered as a result of an allegedly fraudulent and coercive employment recruitment scheme. Plaintiffs filed this suit after District Judge Jay Zainey denied class certification on January 3, 2012 in a related case, David v. Signal International.

Plaintiffs were allegedly brought into the United States to provide labor and services to defendant Signal International. Signal is based in Pascagoula, Mississippi and is in the business of providing repairs to offshore oil rigs in the Gulf Coast region. Three plaintiffs worked at Signal's site in Orange, Texas and one plaintiff worked in Pascagoula. The complaint alleged that plaintiffs paid Signal's recruiters as much as $20,000 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 forced to pay additional fees to live in racially segregated labor camps ($1050 per month), and were subject to squalid living conditions and threats of both legal and physical harm if they complained about the conditions or decided not to provide labor.

Plaintiffs asserted claims under the Trafficking Victims Protection Reauthorization Act (18 U.S.C. §1584 et seq, the Racketeer Influenced Corrupt Organizations Act (18 U.S.C. §1962, the Declaratory Judgment Act (28 U.S.C. §2201), as well as claims of fraud, negligent misrepresentation, and breach of contract. Plaintiffs were represented by a private law firm.

In July 2014, Magistrate Judge Zack Hawthorn denied Signal's motion to transfer this case to the Eastern District of Louisiana. The plaintiffs in this case only overlapped with the David case insofar as their FLSA claims in the David case were concerned. Magistrate Judge Hawthorn found the similarity in issues in the cases was not substantial enough to warrant transfer because the current venue was otherwise proper.

In June 2015, Magistrate Judge Hawthorn severed and transferred Signal's cross-claims against co-defendants (immigration attorneys, recruiters, and labor brokers) to the Eastern District of Louisiana, finding that there was significant overlap between Signal's crossclaims in this case and in David.

In July 2015, the Court stayed the case after Signal filed for bankruptcy. In re Signal Int’l, Inc, et al., No. 15-11498 (Bankr. D. Del. July 12, 2015). As a part of the bankruptcy filings, the plaintiffs entered into a plan support agreement (PSA) which contemplated a settlement of the claims of this lawsuit against Signal entities through a consensual chapter 11 plan proposed by Signal. The PSA became effective on Dec. 14, 2015.

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.

In this case, Meganathan, the Court asked the parties for updates every 120 days as to the status of the bankruptcy proceedings. However, the latest is from Nov. 8, 2016 (simply stating that the proceedings remain ongoing). The bankruptcy case closed on February 5, 2019, however the case remains open and no further updates have been filed.

Summary Authors

Anna Dimon (5/14/2015)

Soojin Cha (11/20/2016)

Ava Morgenstern (12/2/2017)

Caitlin Kierum (11/22/2019)

Related Cases

David v. Signal International, LLC, Eastern District of Louisiana (2008)

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

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

People

For PACER's information on parties and their attrorneys, see: https://www.courtlistener.com/docket/4386366/parties/meganathan-v-signal-international-llc/


Judge(s)

Crone, Marcia A. (Texas)

Hawthorn, Zack (Texas)

Attorneys(s) for Plaintiff

Birnbaum, Timothy H. (New York)

Dodson, John Blake (New York)

Hynes, Michael D. (New York)

Raptis, Stephen T. (District of Columbia)

Sohn, Joshua Samuel (New York)

Solberg, Brett David (Texas)

Attorneys(s) for Defendant

Bollman, Patricia Anne F. (Louisiana)

Cerniglia, Timothy W. (Louisiana)

Judge(s)

Crone, Marcia A. (Texas)

Hawthorn, Zack (Texas)

Attorneys(s) for Plaintiff

Birnbaum, Timothy H. (New York)

Dodson, John Blake (New York)

Hynes, Michael D. (New York)

Raptis, Stephen T. (District of Columbia)

Sohn, Joshua Samuel (New York)

Solberg, Brett David (Texas)

Attorneys(s) for Defendant

Bollman, Patricia Anne F. (Louisiana)

Cerniglia, Timothy W. (Louisiana)

Cornblatt, James L. (Louisiana)

Davis, Lauren Masur (Louisiana)

Hangartner, Erin Casey (Louisiana)

Hasenkampf, Mitchell P. (Louisiana)

Herman, Jonathan Marc (Texas)

Keller, Robert Louis (Louisiana)

Maney, Kevin P. (Louisiana)

Masur Davis, Lauren C. (Louisiana)

Rabbani, Elham (Louisiana)

Roux, Brian C. (Louisiana)

Rydberg, Lance R. (Louisiana)

Sandler, Bradford J. (Delaware)

Ungar, Hal D. (Louisiana)

Weinberger, Alan Dean (Louisiana)

Other Attorney(s)

Adams, Daniel D. (New York)

Arvelo, Jose E. (District of Columbia)

Coco, Nathan F. (Texas)

Colby, Eben P. (Massachusetts)

Dorris, William E. (Georgia)

Ford, Kara D. (Georgia)

Kinsella, Steven R. (Minnesota)

Mintz, Benjamin (New York)

Sabourian, Kayvon (Texas)

Werner, Daniel (Georgia)

Documents in the Clearinghouse

Document

1:13-cv-00497

Docket [PACER]

Nov. 29, 2016

Nov. 29, 2016

Docket
1

1:13-cv-00497

Complaint

Meganathan v. Signal International L.L.C

Aug. 7, 2013

Aug. 7, 2013

Complaint
38

1:13-cv-00497

Report and Recommendations of United States Magistrate Judge

2014 U.S.Dist.LEXIS 126737

July 3, 2014

July 3, 2014

Magistrate Report/Recommendation
44

1:13-cv-00497

Order Denying Defendants Motion to Transfer

Meganthan v. Signal International, LLC

July 16, 2014

July 16, 2014

Order/Opinion
47

1:13-cv-00497

Report and Recommendation Denying Defendant Signal's Motion to Dismiss (Doc. No. 16)

Meganathan v. Signal International, LLC

2014 U.S.Dist.LEXIS 126779

July 29, 2014

July 29, 2014

Magistrate Report/Recommendation
49

1:13-cv-00497

Report and Recommendation Denying the Burnett Defendants' Motion to Dismiss (Doc. No. 11)

Meganthan v. Signal International, LLC

2014 U.S.Dist.LEXIS 126780

July 31, 2014

July 31, 2014

Magistrate Report/Recommendation
102

1:13-cv-00497

Order Severing and Transferring Signal's Cross-Claims to the Eastern District of Louisiana

June 17, 2015

June 17, 2015

Order/Opinion
103

1:13-cv-00497

Memorandum and Order on the Parties' Motions to Exclude Expert Testimony

2015 WL 11109846

June 26, 2015

June 26, 2015

Order/Opinion
279-1

15-11498

Plan Support Agreement

U.S. District Court for the District of Delaware

Sept. 1, 2015

Sept. 1, 2015

Settlement Agreement
109

1:13-cv-00497

Status Report

Nov. 8, 2016

Nov. 8, 2016

Pleading / Motion / Brief

Resources

Docket

See docket on RECAP: https://www.courtlistener.com/docket/4386366/meganathan-v-signal-international-llc/

Last updated Aug. 8, 2022, 3:01 a.m.

ECF Number Description Date Link Date / Link
1

COMPLAINT against All Defendants ( Filing fee $ 400 receipt number 0540-4255184.), filed by Raju Meganathan, Saravanan Ramasamy, Maruthamuthu Mayavu, Saravanachlevan Narayanasamy. (Attachments: # 1 Exhibit 1 - RICO Fraud Chart, # 2 Civil Cover Sheet)(Dodson, John) (Entered: 08/07/2013)

1 Exhibit 1 - RICO Fraud Chart

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2 Civil Cover Sheet

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Aug. 7, 2013

Aug. 7, 2013

PACER

Case Assigned to Judge Marcia A. Crone. (aam, )

Aug. 7, 2013

Aug. 7, 2013

PACER

DEMAND for Trial by Jury by Maruthamuthu Mayavu, Raju Meganathan, Saravanachlevan Narayanasamy and Saravanan Ramasamy. (aam, )

Aug. 7, 2013

Aug. 7, 2013

PACER

In accordance with the provisions of 28 USC Section 636(c), you are hereby notified that a U.S. Magistrate Judge of this district court is available to conduct any or all proceedings in this case including a jury or non-jury trial and to order the entry of a final judgment. The form Consent to Proceed Before Magistrate Judge is available on our website. All signed consent forms, excluding pro se parties, should be filed electronically using the event Notice of Consent to Proceed Before Magistrate Judge. (aam, )

Aug. 8, 2013

Aug. 8, 2013

PACER
2

ORDER REFERRING CASE to Magistrate Judge Zack Hawthorn to conduct all pretrial proceedings. Signed by Judge Marcia A. Crone on 8/8/13. (mrp, ) (Entered: 08/09/2013)

Aug. 8, 2013

Aug. 8, 2013

PACER
3

NOTICE of Attorney Appearance - Pro Hac Vice by Timothy H Birnbaum on behalf of Maruthamuthu Mayavu, Raju Meganathan, Saravanachlevan Narayanasamy, Saravanan Ramasamy. Filing fee paid in the amount of $ 100.00, receipt no. 0540-4263112. (dlc, ) (Entered: 08/13/2013)

Aug. 12, 2013

Aug. 12, 2013

PACER
4

NOTICE of Attorney Appearance - Pro Hac Vice by Joshua Samuel Sohn on behalf of All Plaintiffs. Filing fee $ 100, receipt number 0540-4265921. (Sohn, Joshua) (Entered: 08/14/2013)

Aug. 14, 2013

Aug. 14, 2013

PACER
5

SUMMONS Issued as to Malvern C. Burnett, Global Resources, Inc., Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C., Michael Pol, Signal International L.L.C., Signal International Texas, G.P., Signal International Texas, L.P., and Signal International, Inc. and emailed to plas' atty for service (aam, ) (Entered: 08/20/2013)

Aug. 20, 2013

Aug. 20, 2013

PACER
6

***STRICKEN PER STANDING ORDER MC-12. PLEASE IGNORE.*** Unopposed MOTION for Extension of Time to File Responsive Pleadings by Signal International L.L.C.. (Herman, Jonathan) Modified on 9/9/2013 (bjc, ). (Entered: 09/09/2013)

Sept. 9, 2013

Sept. 9, 2013

PACER
7

***STRICKEN PER STANDING ORDER MC-12. PLEASE IGNORE.*** Unopposed MOTION for Extension of Time to File Responsive Pleadings by Signal International Texas, G.P.. (Herman, Jonathan) Modified on 9/9/2013 (bjc, ). (Entered: 09/09/2013)

Sept. 9, 2013

Sept. 9, 2013

PACER
8

***STRICKEN PER STANDING ORDER MC-12. PLEASE IGNORE.*** Unopposed MOTION for Extension of Time to File Responsive Pleadings by Signal International Texas, L.P.. (Herman, Jonathan) Modified on 9/9/2013 (bjc, ). (Entered: 09/09/2013)

Sept. 9, 2013

Sept. 9, 2013

PACER
9

***STRICKEN PER STANDING ORDER MC-12. PLEASE IGNORE.*** Unopposed MOTION for Extension of Time to File Responsive Pleadings by Signal International, Inc.. (Herman, Jonathan) Modified on 9/9/2013 (bjc, ). (Entered: 09/09/2013)

Sept. 9, 2013

Sept. 9, 2013

PACER

***Documents 6,7,8 and 9 have been stricken in violation of Standing Order MC-12. Attorney has been notified and will file motions for extension of time.*** (bjc)

Sept. 9, 2013

Sept. 9, 2013

PACER
10

MOTION to Dismiss pursuant to FRCP 12(B)(2) by Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C.. (Attachments: # 1 Exhibit 1 - Affidavit, # 2 Text of Proposed Order)(Cerniglia, Timothy) Modified on 9/10/2013 (bjc, ). (Entered: 09/10/2013)

1 Exhibit 1 - Affidavit

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2 Text of Proposed Order

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Sept. 10, 2013

Sept. 10, 2013

PACER
11

MOTION to Dismiss pursuant to FRCP 12(B)(6) by Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C.. (Attachments: # 1 Exhibit 2 - La. Complaint, # 2 Text of Proposed Order)(Cerniglia, Timothy) Modified on 9/10/2013 (bjc, ). (Entered: 09/10/2013)

1 Exhibit 2 - La. Complaint

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2 Text of Proposed Order

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Sept. 10, 2013

Sept. 10, 2013

PACER
12

MOTION to Change Venue by Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C.. (Attachments: # 1 Exhibit 1 - Venue Motion, # 2 Text of Proposed Order)(Cerniglia, Timothy) (Entered: 09/10/2013)

1 Exhibit 1 - Venue Motion

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2 Text of Proposed Order

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Sept. 10, 2013

Sept. 10, 2013

PACER
13

Unopposed MOTION for Extension of Time to File Responsive Pleadings by Signal International L.L.C., Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc.. (Attachments: # 1 Text of Proposed Order)(Herman, Jonathan) (Entered: 09/11/2013)

1 Text of Proposed Order

View on PACER

Sept. 11, 2013

Sept. 11, 2013

PACER

ORAL ORDER granting 13 Motion for Extension of Time to File. Signed by Magistrate Judge Zack Hawthorn on 9/11/13. (zjh1)

Sept. 11, 2013

Sept. 11, 2013

PACER
14

***FILED IN ERROR. PLEASE IGNORE.*** Unopposed MOTION for Extension of Time to File Response/Reply to Defendant Burnett's Motions to Dismiss and to Transfer Venue, and Anticipated Motions by Defendant Signal by Maruthamuthu Mayavu, Raju Meganathan, Saravanachlevan Narayanasamy, Saravanan Ramasamy. (Attachments: # 1 Text of Proposed Order)(Sohn, Joshua) Modified on 9/20/2013 (bjc, ). (Entered: 09/20/2013)

1 Text of Proposed Order

View on PACER

Sept. 20, 2013

Sept. 20, 2013

PACER

***FILED IN ERROR. Document # 14, motion for extension of time. No certificate of service. PLEASE IGNORE. Atty will refile.*** (bjc)

Sept. 20, 2013

Sept. 20, 2013

PACER
15

Unopposed MOTION for Extension of Time to File Response/Reply in Opposition to Defendant Burnett's Motions to Dismiss and to Transfer Venue, and Anticipated Motions by Defendant Signal by Maruthamuthu Mayavu, Raju Meganathan, Saravanachlevan Narayanasamy, Saravanan Ramasamy. (Attachments: # 1 Text of Proposed Order)(Sohn, Joshua) (Entered: 10/11/2013)

1 Text of Proposed Order

View on PACER

Oct. 11, 2013

Oct. 11, 2013

PACER
16

First MOTION to Dismiss Pursuant to Fed. R. Civ. P. 12(b)(6) by Signal International L.L.C., Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc.. Responses due by 10/25/2013 (Attachments: # 1 Text of Proposed Order Proposed Order on Defendants' Motion to Dismiss)(Herman, Jonathan) (Entered: 10/11/2013)

1 Text of Proposed Order Proposed Order on Defendants' Motion to Dismiss

View on PACER

Oct. 11, 2013

Oct. 11, 2013

PACER
17

First MOTION to Change Venue Pursuant to First-Filed Rule by Signal International L.L.C., Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc.. (Attachments: # 1 Exhibit Southern Poverty Law Center. # 2 Exhibit Consent to Sue. # 3 Proposed Order (Herman, Jonathan) Modified on 10/15/2013 (mrp, ). (Entered: 10/11/2013)

1 Exhibit Southern Poverty Law Center press release regarding David v. Signal Intl

View on PACER

2 Exhibit The consent to sue of the lead plaintiff, Meganathan, offered as a repre

View on PACER

3 Text of Proposed Order Proposed Order for Motion of Signal Defendants for Stay P

View on PACER

Oct. 11, 2013

Oct. 11, 2013

PACER

ORAL ORDER granting 15 Motion for Extension of Time to File Response/Reply. Signed by Magistrate Judge Zack Hawthorn on 10/15/13. (zjh1)

Oct. 15, 2013

Oct. 15, 2013

PACER
18

ORDER to Conduct Rule 26(f) Conference with a proposed Scheduling Order. Signed by Magistrate Judge Zack Hawthorn on 11/12/13. (mrp, ) (Entered: 11/13/2013)

Nov. 12, 2013

Nov. 12, 2013

PACER
19

ADVISORY ORDER. This case is assigned for trial to Judge Marcia A. Crone, and is referred to the undersigned Magistrate Judge for pretrial proceedings. Judge Crone's procedures and rules of practice govern this action unless the parties consent to proceed before the Magistrate Judge. Signed by Magistrate Judge Zack Hawthorn on 11/12/13. (mrp, ) (Entered: 11/13/2013)

Nov. 12, 2013

Nov. 12, 2013

PACER
20

RESPONSE in Opposition re 10 MOTION to Dismiss pursuant to FRCP 12(B)(2) of Burnett Defendants filed by Maruthamuthu Mayavu, Raju Meganathan, Saravanachlevan Narayanasamy, Saravanan Ramasamy. (Attachments: # 1 Text of Proposed Order)(Sohn, Joshua) (Entered: 11/15/2013)

1 Text of Proposed Order

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Nov. 15, 2013

Nov. 15, 2013

PACER
21

RESPONSE in Opposition re 11 MOTION to Dismiss pursuant to FRCP 12(B)(6) of Legal Facilitator Defendants filed by Maruthamuthu Mayavu, Raju Meganathan, Saravanachlevan Narayanasamy, Saravanan Ramasamy. (Attachments: # 1 Text of Proposed Order)(Sohn, Joshua) (Entered: 11/15/2013)

1 Text of Proposed Order

View on PACER

Nov. 15, 2013

Nov. 15, 2013

PACER
22

RESPONSE in Opposition re 12 MOTION to Change Venue of Burnett Defendants filed by Maruthamuthu Mayavu, Raju Meganathan, Saravanachlevan Narayanasamy, Saravanan Ramasamy. (Attachments: # 1 Text of Proposed Order)(Sohn, Joshua) (Entered: 11/15/2013)

1 Text of Proposed Order

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Nov. 15, 2013

Nov. 15, 2013

PACER
23

RESPONSE in Opposition re 16 First MOTION to Dismiss Pursuant to Fed. R. Civ. P. 12(b)(6) of Signal Defendants filed by Maruthamuthu Mayavu, Raju Meganathan, Saravanachlevan Narayanasamy, Saravanan Ramasamy. (Attachments: # 1 Text of Proposed Order)(Sohn, Joshua) (Entered: 11/15/2013)

1 Text of Proposed Order

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Nov. 15, 2013

Nov. 15, 2013

PACER
24

RESPONSE in Opposition re 17 First MOTION to Change Venue Pursuant to First-Filed Rule of Signal Defendants filed by Maruthamuthu Mayavu, Raju Meganathan, Saravanachlevan Narayanasamy, Saravanan Ramasamy. (Attachments: # 1 Text of Proposed Order)(Sohn, Joshua) (Entered: 11/15/2013)

1 Text of Proposed Order

View on PACER

Nov. 15, 2013

Nov. 15, 2013

PACER
25

PROTECTIVE ORDER. Signed by Magistrate Judge Zack Hawthorn on 11/18/13. (mrp, ) (Entered: 11/18/2013)

Nov. 18, 2013

Nov. 18, 2013

RECAP
26

NOTICE of Attorney Appearance - Pro Hac Vice by Erin Casey Hangartner on behalf of Signal International L.L.C., Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc.. Filing fee $ 100, receipt number 0540-4408224. (Hangartner, Erin) (Entered: 11/18/2013)

Nov. 18, 2013

Nov. 18, 2013

PACER
27

NOTICE of Change of Address by Erin Casey Hangartner (Hangartner, Erin) (Entered: 01/02/2014)

Jan. 2, 2014

Jan. 2, 2014

PACER
28

REPORT of Rule 26(f) Planning Meeting. (Attachments: # 1 Exhibit 1 - Complaint)(Sohn, Joshua) (Entered: 01/13/2014)

1 Exhibit 1 - Complaint

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Jan. 13, 2014

Jan. 13, 2014

PACER

NOTICE of Hearing: Scheduling Conference set for 1/28/2014 10:00 AM in Ctrm 4 (Beaumont) before Magistrate Judge Zack Hawthorn. (ttp, )

Jan. 13, 2014

Jan. 13, 2014

PACER

NOTICE of Hearing: Telephonic Scheduling Conference set for 2/13/2014 10:30 AM before Magistrate Judge Zack Hawthorn. (ttp, )

Jan. 30, 2014

Jan. 30, 2014

PACER
29

Minute Entry for proceedings held before Magistrate Judge Zack Hawthorn: Scheduling Conference held on 2/13/2014. (DCR Op: Piper, T.) (ttp, ) (Entered: 02/18/2014)

Feb. 13, 2014

Feb. 13, 2014

PACER
30

SCHEDULING ORDER: Docket call is set for 8/7/15 at 10:00 a.m. in Courtroom #3 before Judge Marcia A. Crone. Case will be set for Final Pretrial Conference and Trial at the docket call. Amended Pleadings due by 5/12/2014. Discovery due by 12/15/2014. Motions due by 1/15/2015. Signed by Magistrate Judge Zack Hawthorn on 2/18/14. (mrp, ) (Entered: 02/18/2014)

Feb. 18, 2014

Feb. 18, 2014

PACER
31

MOTION to Withdraw as Attorney Jonathan M. Herman and Middleberg Riddle Group by Signal International L.L.C., Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc.. (Attachments: # 1 Text of Proposed Order)(Herman, Jonathan) (Entered: 04/03/2014)

1 Text of Proposed Order

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April 3, 2014

April 3, 2014

RECAP

ORAL ORDER granting 31 Motion to Withdraw as Attorney. Attorney Jonathan Marc Herman terminated. Signed by Magistrate Judge Zack Hawthorn on 4/4/14. (zjh1)

April 4, 2014

April 4, 2014

PACER
32

NOTICE of Attorney Appearance - Pro Hac Vice by Brian Christopher Roux on behalf of Signal International L.L.C., Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc.. Filing fee $ 100, receipt number 0540-4624088. (Roux, Brian) (Entered: 04/22/2014)

April 22, 2014

April 22, 2014

PACER
33

NOTICE of Attorney Appearance - Pro Hac Vice by Elham R Rabbani on behalf of Signal International L.L.C., Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc.. Filing fee $ 100, receipt number 0540-4672798. (Rabbani, Elham) (Entered: 05/23/2014)

May 23, 2014

May 23, 2014

PACER
34

NOTICE of Attorney Appearance - Pro Hac Vice by Hal D Ungar on behalf of Signal International L.L.C., Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc.. Filing fee $ 100, receipt number 0540-4672872. (Ungar, Hal) (Entered: 05/23/2014)

May 23, 2014

May 23, 2014

PACER
35

NOTICE of Attorney Appearance - Pro Hac Vice by Alan Dean Weinberger on behalf of Signal International L.L.C., Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc.. Filing fee $ 100, receipt number 0540-4672882. (Weinberger, Alan) (Entered: 05/23/2014)

May 23, 2014

May 23, 2014

PACER
36

NOTICE of Attorney Appearance - Pro Hac Vice by Patricia Bollman on behalf of Signal International L.L.C., Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc.. Filing fee $ 100, receipt number 0540-4672901. (Bollman, Patricia) (Entered: 05/23/2014)

May 23, 2014

May 23, 2014

PACER
37

Unopposed MOTION for Entry of Consent Orders Regarding Discovery by Maruthamuthu Mayavu, Raju Meganathan, Saravanachlevan Narayanasamy, Saravanan Ramasamy. (Attachments: # 1 Text of Proposed Order Consent Order Regarding Protocols for the Production of Electronically Stored Information, # 2 Text of Proposed Order Consent Supplemental Protective Order, # 3 Text of Proposed Order Consent Clawback Order, # 4 Text of Proposed Order Consent Order Regarding Use of Discovery from Related Cases)(Sohn, Joshua) (Entered: 07/02/2014)

1 Text of Proposed Order Consent Order Regarding Protocols for the Production of E

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2 Text of Proposed Order Consent Supplemental Protective Order

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3 Text of Proposed Order Consent Clawback Order

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4 Text of Proposed Order Consent Order Regarding Use of Discovery from Related Cas

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July 2, 2014

July 2, 2014

PACER

ORAL ORDER granting 37 Motion. This oral order will act as a signature on the consent orders. Signed by Magistrate Judge Zack Hawthorn on 7-3-2014. (Hawthorn, Zack)

July 3, 2014

July 3, 2014

PACER
38

REPORT AND RECOMMENDATION OF U. S. MAGISTRATE JUDGE that the 10 MOTION to Dismiss should be denied. In summary, the undersigned finds the Plaintiffs have presented sufficient facts to establish a prima facie case of personal jurisdiction over the Defendants because the RICO statute provides for nationwide service of process. Signed by Magistrate Judge Zack Hawthorn on 7/2/14. (mrp, ) (Entered: 07/03/2014)

July 3, 2014

July 3, 2014

RECAP
39

OBJECTION to 38 Report and Recommendation by Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C. (Cerniglia, Timothy) Modified on 7/11/2014 (bjc, ). (Entered: 07/08/2014)

July 8, 2014

July 8, 2014

RECAP
40

NOTICE of Attorney Appearance - Pro Hac Vice by Lance R Rydberg on behalf of Signal International L.L.C., Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc.. Filing fee $ 100, receipt number 0540-4740872. (Rydberg, Lance) (Entered: 07/11/2014)

July 11, 2014

July 11, 2014

PACER
41

OBJECTION to 38 Report and Recommendations by Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C.. (Cerniglia, Timothy) (Entered: 07/14/2014)

July 14, 2014

July 14, 2014

RECAP
42

ADVISORY ORDER CONCERNING PAGE LIMITATIONS FOR APPEALS OF MAGISTRATE JUDGE DECISIONS. Signed by Magistrate Judge Zack Hawthorn on 7/15/14. (mrp, ) (Entered: 07/16/2014)

July 16, 2014

July 16, 2014

RECAP
44

ORDER denying 12 and 17 Defendants' Motions to Change Venue. Signed by Magistrate Judge Zack Hawthorn on 7/16/14. (mrp, ) (Entered: 07/17/2014)

July 16, 2014

July 16, 2014

PACER
43

APPEAL OF MAGISTRATE JUDGE DECISION to District Court by Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C. (Attachments: # 1 Exhibit)(Cerniglia, Timothy) (Entered: 07/17/2014)

1 Exhibit

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July 17, 2014

July 17, 2014

PACER
45

RESPONSE in Opposition to 41 Objection to 38 Report and Recommendation on Motion to Dismiss by Maruthamuthu Mayavu, Raju Meganathan, Saravanachlevan Narayanasamy, Saravanan Ramasamy. (Sohn, Joshua) Modified on 7/22/2014 (tkd, ). (Entered: 07/21/2014)

July 21, 2014

July 21, 2014

RECAP
46

MOTION for Reconsideration re 44 Order by Signal International L.L.C., Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc. (Attachments: # 1 Text of Proposed Order)(Hangartner, Erin) Modified on 7/30/2014 (mrp, ). (Entered: 07/29/2014)

1 Text of Proposed Order

View on PACER

July 29, 2014

July 29, 2014

PACER
47

REPORT AND RECOMMENDATION DENYING 16 First MOTION to Dismiss Pursuant to Fed. R. Civ. P. 12(b)(6). Signed by Magistrate Judge Zack Hawthorn on 7/29/14. (mrp, ) (Entered: 07/30/2014)

July 29, 2014

July 29, 2014

RECAP
48

RESPONSE to 43 Appeal of Magistrate Judge Decision to District Court to Deny Burnett Defendants' Motion to Transfer by Maruthamuthu Mayavu, Raju Meganathan, Saravanachlevan Narayanasamy, Saravanan Ramasamy. (Sohn, Joshua) (Entered: 07/31/2014)

July 31, 2014

July 31, 2014

RECAP
49

REPORT AND RECOMMENDATION DENYING 11 MOTION to Dismiss. The Burnett Defendants' Motion should be denied, subject to reconsideration in a motion for summary judgment that the state law claims are barred by the statute of limitations. Signed by Magistrate Judge Zack Hawthorn on 7/31/14. (mrp, ) (Entered: 08/04/2014)

Aug. 4, 2014

Aug. 4, 2014

RECAP
50

RESPONSE in Opposition re 46 MOTION for Reconsideration re 44 Order filed by Maruthamuthu Mayavu, Raju Meganathan, Saravanachlevan Narayanasamy, Saravanan Ramasamy. (Sohn, Joshua) (Entered: 08/12/2014)

Aug. 12, 2014

Aug. 12, 2014

RECAP
51

ORDER ADOPTING REPORT AND RECOMMENDATION OF U. S. MAGISTRATE JUDGE that 16 Motion to Dismiss filed by Signal International Texas, G.P., et al., is denied. Signed by Judge Marcia A. Crone on 9/9/14. (mrp, ) (Entered: 09/09/2014)

Sept. 9, 2014

Sept. 9, 2014

RECAP
52

ORDER ADOPTING REPORT AND RECOMMENDATION OF U. S. MAGISTRATE JUDGE that the 11 Motion to Dismiss, filed by Gulf Coast Immigration Law Center, L.L.C., Malvern C. Burnett, Law Offices of Malvern C. Burnett, A.P.C. is denied. Signed by Judge Marcia A. Crone on 9/9/14. (mrp, ) (Entered: 09/09/2014)

Sept. 9, 2014

Sept. 9, 2014

RECAP
53

ORDER Adopting Report and Recommendation of U. S. Magistrate Judge # 47 that Motion to Dismiss # 16 is denied. Signed by Judge Marcia A. Crone on 9/9/14. (mrp, ) (Entered: 09/09/2014)

Sept. 9, 2014

Sept. 9, 2014

PACER

***Document # 10 Motion to Dismiss denied by Order Adopting R&R # 51 *** (mrp, )

Sept. 12, 2014

Sept. 12, 2014

PACER
54

NOTICE of Attorney Appearance - Pro Hac Vice by Kevin Patrick Maney on behalf of Signal International L.L.C., Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc.. Filing fee $ 100, receipt number 0540-4832465. (Maney, Kevin) (Entered: 09/12/2014)

Sept. 12, 2014

Sept. 12, 2014

PACER
55

NOTICE of Attorney Appearance - Pro Hac Vice by Robert L Keller, II on behalf of Signal International L.L.C., Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc.. Filing fee $ 100, receipt number 0540-4832940. (Keller, Robert) (Entered: 09/12/2014)

Sept. 12, 2014

Sept. 12, 2014

PACER
56

NOTICE of Attorney Appearance - Pro Hac Vice by James L Cornblatt on behalf of Signal International L.L.C., Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc.. Filing fee $ 100, receipt number 0540-4833648. (Cornblatt, James) (Entered: 09/12/2014)

Sept. 12, 2014

Sept. 12, 2014

PACER
57

NOTICE of Attorney Appearance - Pro Hac Vice by Mitchell P Hasenkampf on behalf of Signal International L.L.C., Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc.. Filing fee $ 100, receipt number 0540-4834369. (Hasenkampf, Mitchell) (Entered: 09/15/2014)

Sept. 15, 2014

Sept. 15, 2014

PACER
58

NOTICE of Attorney Appearance - Pro Hac Vice by Lauren Masur Davis on behalf of Signal International L.L.C., Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc.. Filing fee $ 100, receipt number 0540-4835117. (Davis, Lauren) (Entered: 09/15/2014)

Sept. 15, 2014

Sept. 15, 2014

PACER
59

ORDER denying 46 Motion for Reconsideration of Magistrate's Decision. Signed by Judge Marcia A. Crone on 10/20/2014. (bjc) (Entered: 10/20/2014)

Oct. 20, 2014

Oct. 20, 2014

RECAP
60

ORDERED that Burnett's "Appeal of Magistrate Judges Order, or Alternatively Objection to Magistrates Report and Recommendation to Deny Motion to Transfer Venue (Doc. No. 43) is denied. Signed by Judge Marcia A. Crone on 10/20/2014. (bjc) (Entered: 10/20/2014)

Oct. 20, 2014

Oct. 20, 2014

PACER
61

ANSWER to 1 Complaint,, CROSSCLAIM against Malvern C. Burnett, Sachin Dewan, Dewan Consultants Pvt. Ltd., Global Resources, Inc., Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C., Michael Pol by Signal International Texas, G.P., Signal International, Inc., Signal International L.L.C., Signal International Texas, L.P.. (Attachments: # 1 Exhibit Answer to RICO Fraud Chart)(Hangartner, Erin) (Entered: 10/21/2014)

1 Exhibit Answer to RICO Fraud Chart

View on PACER

Oct. 21, 2014

Oct. 21, 2014

PACER

In accordance with the provisions of 28 USC Section 636(c), you are hereby notified that a U.S. Magistrate Judge of this district court is available to conduct any or all proceedings in this case including a jury or non-jury trial and to order the entry of a final judgment. The form Consent to Proceed Before Magistrate Judge is available on our website. All signed consent forms, excluding pro se parties, should be filed electronically using the event Notice Regarding Consent to Proceed Before Magistrate Judge. (bjc, )

Oct. 22, 2014

Oct. 22, 2014

PACER
62

Unopposed MOTION /to extend deadlines for parties to designate expert witnesses and provide expert reports by Maruthamuthu Mayavu, Raju Meganathan, Saravanachlevan Narayanasamy, Saravanan Ramasamy. (Attachments: # 1 Text of Proposed Order)(Willett, Christopher) Modified on 10/23/2014 (bjc, ). (Entered: 10/23/2014)

1 Text of Proposed Order

View on PACER

Oct. 23, 2014

Oct. 23, 2014

PACER

ORAL ORDER granting 62 Motion for Extension of Time to Designate Expert Witnesses and Provide Expert Reports. Plaintiffs shall designate expert witnesses by November 4, 2014, and Defendants shall designate expert witnesses by December 5, 2014. Signed by Magistrate Judge Zack Hawthorn on 10-23-2014.

Oct. 23, 2014

Oct. 23, 2014

PACER
63

ANSWER to 1 Complaint, by Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C..(Cerniglia, Timothy) (Entered: 11/07/2014)

Nov. 7, 2014

Nov. 7, 2014

RECAP
64

ANSWER to 61 Answer to Complaint, Crossclaim,, by Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C..(Cerniglia, Timothy) (Entered: 11/07/2014)

Nov. 7, 2014

Nov. 7, 2014

RECAP
65

NOTICE by Signal International L.L.C., Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc. of Expert Witness Disclosure (Hangartner, Erin) (Entered: 12/05/2014)

Dec. 5, 2014

Dec. 5, 2014

PACER
66

MOTION for Extension of Time to Complete Discovery (Extend Discovery Deadlines and the Motion Cut-Off) by Signal International L.L.C., Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc.. (Attachments: # 1 Text of Proposed Order, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E)(Hangartner, Erin) (Entered: 12/17/2014)

1 Text of Proposed Order

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2 Exhibit A

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3 Exhibit B

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4 Exhibit C

View on PACER

5 Exhibit D

View on PACER

6 Exhibit E

View on PACER

Dec. 17, 2014

Dec. 17, 2014

RECAP
67

RESPONSE in Opposition re 66 MOTION for Extension of Time to Complete Discovery (Extend Discovery Deadlines and the Motion Cut-Off) filed by Maruthamuthu Mayavu, Raju Meganathan, Saravanachlevan Narayanasamy, Saravanan Ramasamy. (Birnbaum, Timothy) (Entered: 01/05/2015)

Jan. 5, 2015

Jan. 5, 2015

PACER
68

MOTION in Limine to Exclude the Opinion Testimony of Clyde Payne by Signal International L.L.C., Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc.. (Attachments: # 1 Text of Proposed Order, # 2 Exhibit A, # 3 Exhibit B)(Hangartner, Erin) (Entered: 01/15/2015)

1 Text of Proposed Order

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2 Exhibit A

View on PACER

3 Exhibit B

View on PACER

Jan. 15, 2015

Jan. 15, 2015

PACER
69

MOTION in Limine to Exclude/Limit the Testimony of Florence Burke by Signal International L.L.C., Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc.. (Attachments: # 1 Text of Proposed Order, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C)(Hangartner, Erin) (Entered: 01/15/2015)

1 Text of Proposed Order

View on PACER

2 Exhibit A

View on PACER

3 Exhibit B

View on PACER

4 Exhibit C

View on PACER

Jan. 15, 2015

Jan. 15, 2015

PACER
70

MOTION to Exclude the Testimony and Strike the Report of Ron McAlear by Maruthamuthu Mayavu, Raju Meganathan, Saravanachlevan Narayanasamy, Saravanan Ramasamy. (Attachments: # 1 Memorandum of Law, # 2 Declaration, # 3 Exhibit 1, # 4 Exhibit 2, # 5 Exhibit 3, # 6 Exhibit 4, # 7 Text of Proposed Order)(Birnbaum, Timothy) (Entered: 01/15/2015)

1 Memorandum of Law

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2 Declaration

View on PACER

3 Exhibit 1

View on PACER

4 Exhibit 2

View on PACER

5 Exhibit 3

View on PACER

6 Exhibit 4

View on PACER

7 Text of Proposed Order

View on PACER

Jan. 15, 2015

Jan. 15, 2015

PACER
71

MOTION to Exclude the Testimony and Strike the Report of Ronald L. Signorino by Maruthamuthu Mayavu, Raju Meganathan, Saravanachlevan Narayanasamy, Saravanan Ramasamy. (Attachments: # 1 Memorandum of Law, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4, # 6 Declaration, # 7 Text of Proposed Order)(Birnbaum, Timothy) (Entered: 01/15/2015)

1 Memorandum of Law

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2 Exhibit 1

View on PACER

3 Exhibit 2

View on PACER

4 Exhibit 3

View on PACER

5 Exhibit 4

View on PACER

6 Declaration

View on PACER

7 Text of Proposed Order

View on PACER

Jan. 15, 2015

Jan. 15, 2015

PACER
72

MOTION to Exclude the Testimony and Strike the Report of Enrique Gonzalez, III by Maruthamuthu Mayavu, Raju Meganathan, Saravanachlevan Narayanasamy, Saravanan Ramasamy. (Attachments: # 1 Memorandum of Law, # 2 Declaration, # 3 Exhibit A, # 4 Exhibit B, # 5 Text of Proposed Order)(Birnbaum, Timothy) (Entered: 01/15/2015)

1 Memorandum of Law

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2 Declaration

View on PACER

3 Exhibit A

View on PACER

4 Exhibit B

View on PACER

5 Text of Proposed Order

View on PACER

Jan. 15, 2015

Jan. 15, 2015

PACER
73

MOTION to Exclude the Testimony and Strike the Report of Dr. Louise Shelley by Maruthamuthu Mayavu, Raju Meganathan, Saravanachlevan Narayanasamy, Saravanan Ramasamy. (Attachments: # 1 Memorandum of Law, # 2 Declaration, # 3 Exhibit A, # 4 Exhibit B, # 5 Exhibit C, # 6 Exhibit D, # 7 Text of Proposed Order)(Birnbaum, Timothy) (Entered: 01/15/2015)

1 Memorandum of Law

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2 Declaration

View on PACER

3 Exhibit A

View on PACER

4 Exhibit B

View on PACER

5 Exhibit C

View on PACER

6 Exhibit D

View on PACER

7 Text of Proposed Order

View on PACER

Jan. 15, 2015

Jan. 15, 2015

PACER
74

MOTION to Exclude the Testimony and Strike the Report of Virginia Miles by Maruthamuthu Mayavu, Raju Meganathan, Saravanachlevan Narayanasamy, Saravanan Ramasamy. (Attachments: # 1 Memorandum of Law, # 2 Declaration, # 3 Exhibit A, # 4 Text of Proposed Order)(Birnbaum, Timothy) (Entered: 01/15/2015)

1 Memorandum of Law

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2 Declaration

View on PACER

3 Exhibit A

View on PACER

4 Text of Proposed Order

View on PACER

Jan. 15, 2015

Jan. 15, 2015

PACER
75

MOTION to Exclude Testimony and Strike the Expert Report of Donald H. Strobel by Maruthamuthu Mayavu, Raju Meganathan, Saravanachlevan Narayanasamy, Saravanan Ramasamy. (Attachments: # 1 Memorandum of Law, # 2 Declaration, # 3 Exhibit A, # 4 Exhibit B, # 5 Text of Proposed Order)(Birnbaum, Timothy) (Entered: 01/15/2015)

1 Memorandum of Law

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2 Declaration

View on PACER

3 Exhibit A

View on PACER

4 Exhibit B

View on PACER

5 Text of Proposed Order

View on PACER

Jan. 15, 2015

Jan. 15, 2015

PACER
76

MOTION in Limine to Exclude/Limit the Testimony of Amy Mowl by Signal International L.L.C., Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc.. (Attachments: # 1 Exhibit A, # 2 Exhibit B)(Hangartner, Erin) (Additional attachment(s) added on 1/16/2015: # 3 Text of Proposed Order) (mrp, ). (Entered: 01/15/2015)

1 Exhibit A

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2 Exhibit B

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3 Text of Proposed Order

View on PACER

Jan. 15, 2015

Jan. 15, 2015

PACER
77

MOTION to Exclude the Testimony and Strike the Report of Dr. Kevin Fox Gotham by Maruthamuthu Mayavu, Raju Meganathan, Saravanachlevan Narayanasamy, Saravanan Ramasamy. (Attachments: # 1 Memorandum, # 2 Declaration, # 3 Exhibit A, # 4 Exhibit B, # 5 Exhibit C, # 6 Text of Proposed Order)(Birnbaum, Timothy) (Entered: 01/15/2015)

1 Memorandum

View on PACER

2 Declaration

View on PACER

3 Exhibit A

View on PACER

4 Exhibit B

View on PACER

5 Exhibit C

View on PACER

6 Text of Proposed Order

View on PACER

Jan. 15, 2015

Jan. 15, 2015

PACER
78

REPLY to Response to Motion re 66 MOTION for Extension of Time to Complete Discovery (Extend Discovery Deadlines and the Motion Cut-Off) Reply to Plaintiffs' Opposition to Signals' Motion for Extension of Time to Complete Discovery filed by Signal International L.L.C., Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc.. (Hangartner, Erin) (Entered: 01/16/2015)

Jan. 16, 2015

Jan. 16, 2015

PACER
79

RESPONSE in Opposition re 70 MOTION to Exclude the Testimony and Strike the Report of Ron McAlear filed by Signal International L.L.C., Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc.. (Hangartner, Erin) (Entered: 01/29/2015)

Jan. 29, 2015

Jan. 29, 2015

PACER
80

RESPONSE in Opposition re 72 MOTION to Exclude the Testimony and Strike the Report of Enrique Gonzalez, III filed by Signal International L.L.C., Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc.. (Attachments: # 1 Exhibit A - Expert Report of Gonzalez, # 2 Exhibit B - relevant portions of Gonzalez depo, # 3 Exhibit C - Speaking Engagements of Gonzalez)(Hangartner, Erin) (Entered: 01/29/2015)

1 Exhibit A - Expert Report of Gonzalez

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2 Exhibit B - relevant portions of Gonzalez depo

View on PACER

3 Exhibit C - Speaking Engagements of Gonzalez

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Jan. 29, 2015

Jan. 29, 2015

PACER
81

RESPONSE in Opposition re 71 MOTION to Exclude the Testimony and Strike the Report of Ronald L. Signorino filed by Signal International L.L.C., Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc.. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D)(Hangartner, Erin) (Entered: 01/29/2015)

1 Exhibit A

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2 Exhibit B

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3 Exhibit C

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4 Exhibit D

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Jan. 29, 2015

Jan. 29, 2015

PACER
82

ORDER granting 66 Motion for Extension of Time to Complete Discovery. Discovery shall be completed by 4/1/15 and Motion cut-off is 4/15/15. Signed by Magistrate Judge Zack Hawthorn on 1/30/15. (mrp, ) (Entered: 01/30/2015)

Jan. 30, 2015

Jan. 30, 2015

PACER
83

***FILED IN ERROR WITH INCORRECT EXHIBITS; SEE CORRECTED DOC # 84 *** RESPONSE in Opposition re 77 MOTION to Exclude the Testimony and Strike the Report of Dr. Kevin Fox Gotham filed by Signal International L.L.C., Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc.. (Attachments: # 1 Exhibit 1 - Relevant portions of depo of Richard Marler, # 2 Exhibit 2 - Relevant portions of depo of Lisa Spears, # 3 Exhibit 3 - Info considered by Kevin Gotham, # 4 Exhibit 4 - CV of Kevin Gotham, # 5 Exhibit 5 Revelant portions of depo of KevinGotham)(Hangartner, Erin) Modified on 2/3/2015 (mrp, ). (Entered: 01/30/2015)

1 Exhibit 1 - Relevant portions of depo of Richard Marler

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2 Exhibit 2 - Relevant portions of depo of Lisa Spears

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3 Exhibit 3 - Info considered by Kevin Gotham

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4 Exhibit 4 - CV of Kevin Gotham

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5 Exhibit 5 Revelant portions of depo of KevinGotham

View on PACER

Jan. 30, 2015

Jan. 30, 2015

PACER
84

RESPONSE in Opposition re 77 MOTION to Exclude the Testimony and Strike the Report of Dr. Kevin Fox Gotham filed by Signal International L.L.C., Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc.. (Attachments: # 1 Exhibit 1 - David (-8-1220) Order Doc 2197, # 2 Exhibit 2 - 6-15-2014 Depo of Richard Marler, p. 76-78, # 3 Exhibit 3 - 6-13-14 depo of Lisa Spears, p. 426-428)(Hangartner, Erin) (Entered: 01/30/2015)

1 Exhibit 1 - David (-8-1220) Order Doc 2197

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2 Exhibit 2 - 6-15-2014 Depo of Richard Marler, p. 76-78

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3 Exhibit 3 - 6-13-14 depo of Lisa Spears, p. 426-428

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Jan. 30, 2015

Jan. 30, 2015

PACER
85

RESPONSE in Opposition re 69 MOTION in Limine to Exclude/Limit the Testimony of Florence Burke filed by Maruthamuthu Mayavu, Raju Meganathan, Saravanachlevan Narayanasamy, Saravanan Ramasamy. (Attachments: # 1 Exhibit A)(Birnbaum, Timothy) (Entered: 02/02/2015)

1 Exhibit A

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Feb. 2, 2015

Feb. 2, 2015

PACER
86

RESPONSE in Opposition re 76 MOTION in Limine to Exclude/Limit the Testimony of Amy Mowl filed by Maruthamuthu Mayavu, Raju Meganathan, Saravanachlevan Narayanasamy, Saravanan Ramasamy. (Attachments: # 1 Exhibit 1)(Birnbaum, Timothy) (Entered: 02/02/2015)

1 Exhibit 1

View on PACER

Feb. 2, 2015

Feb. 2, 2015

PACER

Case Details

State / Territory: Texas

Case Type(s):

Immigration and/or the Border

Special Collection(s):

Signal International Guest Worker Cases

Multi-LexSum (in sample)

Key Dates

Filing Date: Aug. 7, 2013

Case Ongoing: Yes

Plaintiffs

Plaintiff Description:

4 Indian guestworkers fraudulently recruited to work in the U.S.

Plaintiff Type(s):

Private Plaintiff

Attorney Organizations:

Southern Poverty Law Center

Public Interest Lawyer: No

Filed Pro Se: No

Class Action Sought: No

Class Action Outcome: Not sought

Defendants

Michael Pol, None

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

Global Resources, Inc., Private Entity/Person

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

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

Malvern C. Burnett (New Orleans, LA), None

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

Signal International, Inc. (Pascagoula, MS), 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.

Declaratory Judgment Act, 28 U.S.C. § 2201

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

Availably Documents:

Trial Court Docket

Complaint (any)

Monetary Relief

Non-settlement Outcome

Any published opinion

Outcome

Prevailing Party: Plaintiff

Nature of Relief:

Damages

Source of Relief:

Settlement

Form of Settlement:

Private Settlement Agreement

Amount Defendant Pays: 5,000,000

Issues

General:

Bathing and hygiene

Disparate Treatment

Fines/Fees/Bail/Bond

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