Case: Kambala v. Signal International, LLC

1:13-cv-00498 | 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, 16 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 Jan. 3, 2012 in a related case, David v. Signal Internat…

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, 16 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 Jan. 3, 2012 in a related case, David v. Signal International. The amended complaint, filed on behalf of 21 individuals, asserted claims under the Trafficking Victims Protection Act (18 U.S.C. §1589 (forced labor) and 18 U.S.C. §1590 (trafficking)), the Racketeer Influenced Corrupt Organizations Act (18 U.S.C. §1962), the Civil Rights Act of 1866 (42 U.S.C. §1981), the Ku Kux Klan Act of 1871 (42 U.S.C. §1985), the Thirteenth Amendment, as well as claims of fraud, negligent misrepresentation, and breach of contract. Plaintiffs were represented by the Equal Justice Center and the Transnational Worker Rights Clinic.

Plaintiffs were allegedly brought into the United States to provide labor and services to defendant Signal International. Signal was based in Pascagoula, Mississippi and was in the business of providing repairs to offshore oil rigs in the Gulf Coast region. One plaintiff worked in Pascagoula; the remaining plaintiffs worked at Signal's Orange, Texas site. The complaint alleged that plaintiffs paid defendant Signal's recruiters as much as $25,000 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 ($1050 per month) to live in racially segregated labor camps, 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.

In July 2014, U.S. 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 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.

Trial was set for December 2015. However, 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, with a liquidation trust for distribution of settlement proceeds, 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, the parties were to update the court every 120 days as to the status of the bankruptcy proceedings. The parties' report on July 5, 2018 noted that 20 of the 21 plaintiffs had reached a settlement with the Burnett (immigration attorney) defendants, and the remaining one plaintiff could not be located. The plaintiffs advised that they would be dismissing their claims against them soon because the Burnett defendants had met their obligations under the settlement. Plaintiffs requested the stay remain in effect as to the Signal defendants and Dewan (recruiter) defendants.

On August 24, 2018, Magistrate Judge Hawthorn issued a report and recommendation to dismiss without prejudice the one remaining plaintiff who did not respond to the court’s order. District Judge Ron Judge Clark adopted the report and recommendation on September 12, 2018 and dismissed this plaintiff without prejudice.

The case is ongoing as to the Signal defendants and Dewan defendants. As of August 2, 2020, there has been no changes in the docket.

Summary Authors

Anna Dimon (5/14/2015)

Ava Morgenstern (3/14/2018)

Sichun Liu (8/2/2020)

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/4386367/parties/kambala-v-signal-international-llc/


Judge(s)

Clark, Ron (Texas)

Hawthorn, Zack (Texas)

Attorneys(s) for Plaintiff

Beardall, William H. Jr. (Texas)

Sabourian, Kayvon (Texas)

Willett, Christopher Joseph (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)

Judge(s)

Clark, Ron (Texas)

Hawthorn, Zack (Texas)

Attorneys(s) for Plaintiff

Beardall, William H. Jr. (Texas)

Sabourian, Kayvon (Texas)

Willett, Christopher Joseph (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)

Shapiro, Stephen H. (Louisiana)

Ungar, Hal D. (Louisiana)

Weinberger, Alan Dean (Louisiana)

Documents in the Clearinghouse

Document

1:13-cv-00498

Docket

Kambala v. Signal International LLC

Sept. 12, 2018

Sept. 12, 2018

Docket
1

1:13-cv-00498

Complaint

Kambala v. Signal International LLC

Aug. 7, 2013

Aug. 7, 2013

Complaint
56

1:13-cv-00498

Order Denying Defendants' Motion to Transfer

July 16, 2014

July 16, 2014

Order/Opinion
117

1:13-cv-00498

Third Amended Complaint

May 6, 2015

May 6, 2015

Complaint
131

1:13-cv-00498

Plaintiff's Status Report

Kambala v. Signal International L.L.C.

April 3, 2017

April 3, 2017

Pleading / Motion / Brief
132

1:13-cv-00498

Status Report

Kambala v. Signal International LLC

Nov. 6, 2017

Nov. 6, 2017

Pleading / Motion / Brief
133

1:13-cv-00498

Status Report

March 6, 2018

March 6, 2018

Pleading / Motion / Brief
138

1:13-cv-00498

Report and Recommendation Dismissing Plaintiff Dalli

Aug. 24, 2018

Aug. 24, 2018

Magistrate Report/Recommendation

Resources

Docket

See docket on RECAP: https://www.courtlistener.com/docket/4386367/kambala-v-signal-international-llc/

Last updated Aug. 4, 2022, 3:04 a.m.

ECF Number Description Date Link Date / Link
1

COMPLAINT against All Defendants ( Filing fee $ 400 receipt number 0540-4255246.), filed by Malkiah Paul, Harbans Singh, Srinivasa Rao Gonna, Srinivasa Rao Kambala, Unnikrishna Pillai Balakrishna Pillai, Pradeep Kumar, Antony Antony Valilyaparambil, Amandeep Singh Kang, Ponniah Muthu Kumar, Harvinder Singh, Abdullah Keepurath Maideen, Francis Sequira, Annadurai Ruthirapathi, Saravanan Arunachalam, Mahendran Periyasamy, Chandra Sekhar Dwadasi Rama. (Attachments: # 1 Exhibit RICO Fraud Chart, # 2 Civil Cover Sheet)(Willett, Christopher) (Entered: 08/07/2013)

1 Exhibit RICO Fraud Chart

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2 Civil Cover Sheet

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Aug. 7, 2013

Aug. 7, 2013

RECAP

Case assigned to Judge Ron Clark. (pkb, )

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. (pkb, )

Aug. 8, 2013

Aug. 8, 2013

PACER
2

ORDER REFERRING CASE to Magistrate Judge Zack Hawthorn for all pretrial proceedings. Signed by Judge Ron Clark on 8/9/13. (tkd, ) (Entered: 08/12/2013)

Aug. 12, 2013

Aug. 12, 2013

PACER
3

SUMMONS Issued and emailed to attorney Christopher Willett for service in case as to Dewan Consultants PVT. LTD., Global Resources, Inc., Gulf Coast Immigration Law Center, L.L.C., Indo-Ameri Soft, L.L.C., J & M Associates of Mississippi, Inc., J & M Marine & Industrial, LLC, Signal International Texas, L.P. and Billy R. Wilks. (Attachments: # 1 Summons(es), # 2 Summons(es), # 3 Summons(es), # 4 Summons(es), # 5 Summons(es), # 6 Summons(es), # 7 Summons(es))(pkb, ) (Entered: 08/13/2013)

1 Summons(es)

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2 Summons(es)

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3 Summons(es)

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4 Summons(es)

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5 Summons(es)

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6 Summons(es)

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7 Summons(es)

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Aug. 13, 2013

Aug. 13, 2013

PACER
4

SUMMONS Issued and emailed to attorney Christopher Willett for service in case as to Sachin Dewan, Law Offices of Malvern C. Burnett, A.P.C., Malvern C. Burnett, Michael Pol, Kurella Rao, Signal International LLC, Signal International Texas, G.P. and Signal International, Inc. (Attachments: # 1 Summons(es), # 2 Summons(es), # 3 Summons(es), # 4 Summons(es), # 5 Summons(es), # 6 Summons(es), # 7 Summons(es))(pkb, ) (Entered: 08/13/2013)

1 Summons(es)

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2 Summons(es)

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3 Summons(es)

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4 Summons(es)

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5 Summons(es)

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6 Summons(es)

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7 Summons(es)

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Aug. 13, 2013

Aug. 13, 2013

PACER
5

NOTICE of Attorney Appearance - Pro Hac Vice by Kayvon Sabourian on behalf of All Plaintiffs. Filing fee $ 100, receipt number 0540-4322831. (Sabourian, Kayvon) (Entered: 09/19/2013)

Sept. 19, 2013

Sept. 19, 2013

PACER
6

AMENDED COMPLAINT against Sachin Dewan, Dewan Consultants PVT. LTD., Global Resources, Inc., Gulf Coast Immigration Law Center, L.L.C., Indo-Ameri Soft, L.L.C., J & M Associates of Mississippi, Inc., J & M Marine & Industrial, LLC, Law Offices of Malvern C. Burnett, A.P.C., Malvern C. Burnett, Kurella Rao, Signal International LLC, Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Billy R. Wilks, filed by Malkiah Paul, Harbans Singh, Srinivasa Rao Gonna, Srinivasa Rao Kambala, Unnikrishna Pillai Balakrishna Pillai, Pradeep Kumar, Amandeep Singh Kang, Ponniah Muthu Kumar, Harvinder Singh, Abdullah Keepurath Maideen, Francis Sequira, Annadurai Ruthirapathi, Saravanan Arunachalam, Mahendran Periyasamy, Chandra Sekhar Dwadasi Rama. (Attachments: # 1 Exhibit RICO Fraud Chart)(Willett, Christopher) (Entered: 10/03/2013)

1 Exhibit RICO Fraud Chart

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Oct. 3, 2013

Oct. 3, 2013

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7

SUMMONS Issued as to Sachin Dewan, Dewan Consultants PVT. LTD and mailed via USPS to attorney Christopher Willett to perfect service. (Attachments: # 1 Summons(es))(pkb, ) (Entered: 10/23/2013)

1 Summons(es)

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Oct. 23, 2013

Oct. 23, 2013

PACER
8

MOTION for Extension of Time to File Answer re 1 Complaint and 6 Amended Complaint by Billy R. Wilks. (Attachments: # 1 Envelope(s))(pkb, ) (Entered: 11/07/2013)

1 Envelope(s)

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Nov. 6, 2013

Nov. 6, 2013

PACER
9

WAIVERS OF SERVICE Returned Executed by Srinivasa Rao Kambala. Signal International LLC; Signal International Texas, G.P.; Signal International Texas, L.P. and Signal International, Inc. waivers sent on 10/7/2013, answers due 12/6/2013. (tkd, ) (Entered: 11/08/2013)

Nov. 8, 2013

Nov. 8, 2013

PACER
10

WAIVER OF SERVICE Returned Executed by Srinivasa Rao Kambala. Indo-Ameri Soft, L.L.C. and Kurella Rao (located in Belize) waivers sent on 10/16/2013, answers due 1/14/2014. (tkd, ) (Entered: 11/08/2013)

Nov. 8, 2013

Nov. 8, 2013

PACER
11

ORDER granting 8 Motion for Extension of Time to Answer. Wilks has until December 8, 2013, to file an answer. Signed by Magistrate Judge Zack Hawthorn on 11/8/2013. (bjc) (Entered: 11/08/2013)

Nov. 8, 2013

Nov. 8, 2013

PACER

Set/Reset Deadlines: Billy R. Wilks answer due 12/8/2013. (bjc)

Nov. 8, 2013

Nov. 8, 2013

PACER
12

SUMMONS Returned Executed by Srinivasa Rao Kambala. Billy Wilks served on 10/27/13. (tkd, ) (Entered: 11/13/2013)

Nov. 12, 2013

Nov. 12, 2013

PACER
13

SUMMONS Returned Executed by Srinivasa Rao Kambala. J & M Associates of Mississippi, Inc. and J & M Marine & Industrial, LLC served on 10/27/2013, answers due 11/18/2013. (tkd, ) (Entered: 11/13/2013)

Nov. 12, 2013

Nov. 12, 2013

PACER
14

MOTION for Stay Pendente Lite and for Transfer Pursuant to First-Filed Rule by Signal International LLC, Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc.. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Text of Proposed Order, # 5 Text of Proposed Order)(Herman, Jonathan) Modified on 12/6/2013 (tkd, ). (Entered: 12/05/2013)

1 Exhibit 1

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2 Exhibit 2

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3 Exhibit 3

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4 Text of Proposed Order

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5 Text of Proposed Order

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Dec. 5, 2013

Dec. 5, 2013

PACER
15

MOTION Extension of Time for Service of Defendants by Saravanan Arunachalam, Chandra Sekhar Dwadasi Rama, Srinivasa Rao Gonna, Srinivasa Rao Kambala, Amandeep Singh Kang, Ponniah Muthu Kumar, Pradeep Kumar, Abdullah Keepurath Maideen, Malkiah Paul, Mahendran Periyasamy, Annadurai Ruthirapathi, Francis Sequira, Harbans Singh, Harvinder Singh, Antony Antony Valilyaparambil. (Attachments: # 1 Text of Proposed Order)(Willett, Christopher) (Entered: 12/05/2013)

1 Text of Proposed Order

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Dec. 5, 2013

Dec. 5, 2013

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16

MOTION to Dismiss Pursuant to FRCP 12(b)(6) by Signal International LLC, Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc.. (Attachments: # 1 Text of Proposed Order)(Herman, Jonathan) Modified on 12/6/2013 (tkd, ). (Entered: 12/05/2013)

1 Text of Proposed Order

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Dec. 5, 2013

Dec. 5, 2013

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17

ADVISORY to the Parties. Signed by Magistrate Judge Zack Hawthorn on 12/11/13. (tkd, ) (Entered: 12/12/2013)

Dec. 12, 2013

Dec. 12, 2013

PACER
18

ORDER to Conduct Rule 26(f) Conference by 12/20/13 and file a joint report by 1/3/14. Signed by Magistrate Judge Zack Hawthorn on 12/11/13. (tkd, ) (Entered: 12/12/2013)

Dec. 12, 2013

Dec. 12, 2013

PACER
19

NOTICE of Attorney Appearance - Pro Hac Vice by Erin Casey Hangartner on behalf of Signal International LLC, Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc.. Filing fee $ 100, receipt number 0540-4449171. (Hangartner, Erin) (Entered: 12/18/2013)

Dec. 18, 2013

Dec. 18, 2013

PACER
20

RESPONSE in Opposition re 16 MOTION to Dismiss Pursuant to FRCP 12(b)(6) filed by Saravanan Arunachalam, Unnikrishna Pillai Balakrishna Pillai, Chandra Sekhar Dwadasi Rama, Srinivasa Rao Gonna, Srinivasa Rao Kambala, Amandeep Singh Kang, Ponniah Muthu Kumar, Pradeep Kumar, Abdullah Keepurath Maideen, Malkiah Paul, Mahendran Periyasamy, Annadurai Ruthirapathi, Francis Sequira, Harbans Singh, Harvinder Singh, Antony Antony Valilyaparambil. (Attachments: # 1 Text of Proposed Order)(Willett, Christopher) (Additional attachment(s) added on 12/26/2013: # 2 Revised Proposed Order) (tkd, ). (Entered: 12/23/2013)

1 Text of Proposed Order

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2 Revised Proposed Order

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Dec. 23, 2013

Dec. 23, 2013

PACER
21

RESPONSE in Opposition re 14 MOTION for Stay Pendent Lite and for Transfer Pursuant to First-Filed Rule filed by Saravanan Arunachalam, Unnikrishna Pillai Balakrishna Pillai, Chandra Sekhar Dwadasi Rama, Srinivasa Rao Gonna, Srinivasa Rao Kambala, Amandeep Singh Kang, Ponniah Muthu Kumar, Pradeep Kumar, Abdullah Keepurath Maideen, Malkiah Paul, Mahendran Periyasamy, Annadurai Ruthirapathi, Francis Sequira, Harbans Singh, Harvinder Singh, Antony Antony Valilyaparambil. (Attachments: # 1 Exhibit H-2B Application (TWC), # 2 Text of Proposed Order)(Willett, Christopher) (Additional attachment(s) added on 12/26/2013: # 3 Revised Proposed Order) (tkd, ). (Entered: 12/23/2013)

1 Exhibit H-2B Application (TWC)

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2 Text of Proposed Order

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3 Revised Proposed Order

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Dec. 23, 2013

Dec. 23, 2013

PACER
22

RESPONSE in Support re 14 MOTION for Stay Pendent Lite and for Transfer Pursuant to First-Filed Rule filed by Signal International LLC, Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc.. (Hangartner, Erin) (Entered: 12/31/2013)

Dec. 31, 2013

Dec. 31, 2013

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

Jan. 2, 2014

Jan. 2, 2014

PACER
24

REPORT of Rule 26(f) Planning Meeting by All Plaintiffs and Signal Defendants. (Willett, Christopher) Modified on 1/6/2014 (bjc, ). (Entered: 01/03/2014)

Jan. 3, 2014

Jan. 3, 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. 6, 2014

Jan. 6, 2014

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25

PROTECTIVE ORDER. Signed by Magistrate Judge Zack Hawthorn on 1/8/2014. (bjc) (Entered: 01/08/2014)

Jan. 8, 2014

Jan. 8, 2014

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ORAL ORDER granting 15 Motion for Extension of Time for Service. Signed by Magistrate Judge Zack Hawthorn on 1/9/14. (zjh1)

Jan. 9, 2014

Jan. 9, 2014

PACER
26

NOTICE of Discovery Disclosure by Saravanan Arunachalam, Unnikrishna Pillai Balakrishna Pillai, Chandra Sekhar Dwadasi Rama, Srinivasa Rao Gonna, Srinivasa Rao Kambala, Amandeep Singh Kang, Ponniah Muthu Kumar, Pradeep Kumar, Abdullah Keepurath Maideen, Malkiah Paul, Mahendran Periyasamy, Annadurai Ruthirapathi, Francis Sequira, Harbans Singh, Harvinder Singh, Antony Antony Valilyaparambil Pursuant to Local Rule CV-26(c) (Willett, Christopher) (Entered: 01/10/2014)

Jan. 10, 2014

Jan. 10, 2014

PACER
27

SUMMONSES Issued as to 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., Malvern C. Burnett and emailed to plf's attorney for service. (tkd, ) (Entered: 01/22/2014)

Jan. 22, 2014

Jan. 22, 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
28

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
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SCHEDULING ORDER setting various deadlines. Final Pretrial Conference set for 12/3/2015 at 9:00 AM and Jury Selection/Trial set for 12/7/2015 at 9:00 AM - all to be held in Ctrm 2 (Beaumont) before Judge Ron Clark. Signed by Magistrate Judge Zack Hawthorn on 2/18/14. (tkd, ) (Entered: 02/18/2014)

Feb. 18, 2014

Feb. 18, 2014

PACER
30

WAIVER OF SERVICE Returned Executed by Srinivasa Rao Kambala. Gulf Coast Immigration Law Center, L.L.C, Law Offices of Malvern C. Burnett, A.P.C., Malvern C. Burnett waiver sent on 1/23/2014; answers due 3/24/2014. (tkd, ) (Entered: 02/28/2014)

Feb. 27, 2014

Feb. 27, 2014

PACER
31

MOTION to Transfer Venue by Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C., Malvern C. Burnett. (Attachments: # 1 La Complaint - David v signal, # 2 Order - Achari v Signal, # 3 Proposed Order)(Cerniglia, Timothy) Modified on 3/24/2014 (tkd, ). (Entered: 03/21/2014)

1 Exhibit La Complaint - David v signal

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2 Exhibit Order - Achari v Signal

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3 Text of Proposed Order

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March 21, 2014

March 21, 2014

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32

MOTION to Dismiss for Lack of Jurisdiction by Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C., Malvern C. Burnett. (Attachments: # 1 Exhibit Affidavit of Burnett, # 2 Text of Proposed Order)(Cerniglia, Timothy) (Entered: 03/21/2014)

1 Exhibit Affidavit of Burnett

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2 Text of Proposed Order

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March 21, 2014

March 21, 2014

PACER
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MOTION to Dismiss by Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C., Malvern C. Burnett. (Attachments: # 1 Text of Proposed Order)(Cerniglia, Timothy) (Entered: 03/21/2014)

1 Text of Proposed Order

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March 21, 2014

March 21, 2014

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34

WAIVER OF SERVICE Returned Executed by Srinivasa Rao Kambala. Sachin Dewan and Dewan Consultants PVT. LTD. waivers sent on 2/19/2014, answers due 4/21/2014. (tkd, ) (Entered: 03/25/2014)

March 21, 2014

March 21, 2014

PACER
35

MOTION to Withdraw as Attorney Jonathan M. Herman and Middleberg Riddle Group by Signal International LLC, 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

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ORAL ORDER granting 35 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

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36

RESPONSE in Opposition re 32 MOTION to Dismiss for Lack of Jurisdiction filed by Saravanan Arunachalam, Unnikrishna Pillai Balakrishna Pillai, Chandra Sekhar Dwadasi Rama, Srinivasa Rao Gonna, Srinivasa Rao Kambala, Amandeep Singh Kang, Ponniah Muthu Kumar, Pradeep Kumar, Abdullah Keepurath Maideen, Malkiah Paul, Mahendran Periyasamy, Annadurai Ruthirapathi, Francis Sequira, Harbans Singh, Harvinder Singh, Antony Antony Valilyaparambil. (Attachments: # 1 Exhibit Willett Declaration, # 2 Text of Proposed Order)(Willett, Christopher) (Entered: 04/07/2014)

1 Exhibit Willett Declaration

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2 Text of Proposed Order

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April 7, 2014

April 7, 2014

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RESPONSE in Opposition re 33 MOTION to Dismiss filed by Saravanan Arunachalam, Unnikrishna Pillai Balakrishna Pillai, Chandra Sekhar Dwadasi Rama, Srinivasa Rao Gonna, Srinivasa Rao Kambala, Amandeep Singh Kang, Ponniah Muthu Kumar, Pradeep Kumar, Abdullah Keepurath Maideen, Malkiah Paul, Mahendran Periyasamy, Annadurai Ruthirapathi, Francis Sequira, Harbans Singh, Harvinder Singh, Antony Antony Valilyaparambil. (Attachments: # 1 Text of Proposed Order)(Willett, Christopher) (Entered: 04/07/2014)

1 Text of Proposed Order

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April 7, 2014

April 7, 2014

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RESPONSE in Opposition re 31 MOTION to Transfer Venue filed by Saravanan Arunachalam, Unnikrishna Pillai Balakrishna Pillai, Chandra Sekhar Dwadasi Rama, Srinivasa Rao Gonna, Srinivasa Rao Kambala, Amandeep Singh Kang, Ponniah Muthu Kumar, Pradeep Kumar, Abdullah Keepurath Maideen, Malkiah Paul, Mahendran Periyasamy, Annadurai Ruthirapathi, Francis Sequira, Harbans Singh, Harvinder Singh, Antony Antony Valilyaparambil. (Attachments: # 1 Exhibit, # 2 Text of Proposed Order)(Willett, Christopher) (Entered: 04/07/2014)

1 Exhibit

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2 Text of Proposed Order

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April 7, 2014

April 7, 2014

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SECOND AMENDED COMPLAINT against Sachin Dewan, Dewan Consultants PVT. LTD., Global Resources, Inc., Gulf Coast Immigration Law Center, L.L.C., Indo-Ameri Soft, L.L.C., J & M Associates of Mississippi, Inc., J & M Marine & Industrial, LLC, Law Offices of Malvern C. Burnett, A.P.C., Malvern C. Burnett, Kurella Rao, Signal International LLC, Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Billy R. Wilks, filed by All Plaintiffs. (Attachments: # 1 Exhibit RICO Fraud Chart)(Willett, Christopher) Modified on 4/14/2014 (tkd, ). (Entered: 04/11/2014)

1 Exhibit RICO Fraud Chart

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April 11, 2014

April 11, 2014

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NOTICE of Attorney Appearance - Pro Hac Vice by Brian Christopher Roux on behalf of Signal International LLC, Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc.. Filing fee $ 100, receipt number 0540-4624098. (Roux, Brian) (Entered: 04/22/2014)

April 22, 2014

April 22, 2014

PACER
41

ORDER denying as moot and without prejudice 16, 32 and 33 Motions to Dismiss. Signed by Magistrate Judge Zack Hawthorn on 4/25/14. (tkd, ) (Entered: 04/25/2014)

April 25, 2014

April 25, 2014

PACER
42

MOTION for Extension of Time to File Answer re 39 Amended Complaint by Signal International LLC, Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc.. (Attachments: # 1 Text of Proposed Order)(Hangartner, Erin) Modified on 4/30/2014 (tkd, ). (Entered: 04/29/2014)

1 Text of Proposed Order

View on PACER

April 29, 2014

April 29, 2014

PACER
43

MOTION to Reassert Motions to Dismiss by Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C., Malvern C. Burnett. (Attachments: # 1 Text of Proposed Order)(Cerniglia, Timothy) Modified on 4/30/2014 (tkd, ). (Entered: 04/29/2014)

1 Text of Proposed Order

View on PACER

April 29, 2014

April 29, 2014

PACER

ORAL ORDER granting 42 Motion for Extension of Time to Answer. Signed by Magistrate Judge Zack Hawthorn on 5/1/14. (zjh1)

May 1, 2014

May 1, 2014

PACER
44

NOTICE of Attorney Appearance - Pro Hac Vice by Alan Dean Weinberger on behalf of Signal International LLC, Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc.. Filing fee $ 100, receipt number 0540-4652432. (Weinberger, Alan) (Entered: 05/09/2014)

May 9, 2014

May 9, 2014

PACER
45

NOTICE of Attorney Appearance - Pro Hac Vice by Patricia Bollman on behalf of Signal International LLC, Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc.. Filing fee $ 100, receipt number 0540-4652449. (Bollman, Patricia) (Entered: 05/09/2014)

May 9, 2014

May 9, 2014

PACER
46

NOTICE of Attorney Appearance - Pro Hac Vice by Hal D Ungar on behalf of Signal International LLC, Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc.. Filing fee $ 100, receipt number 0540-4652471. (Ungar, Hal) (Entered: 05/09/2014)

May 9, 2014

May 9, 2014

PACER
47

NOTICE of Attorney Appearance - Pro Hac Vice by Elham R Rabbani on behalf of Signal International LLC, Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc.. Filing fee $ 100, receipt number 0540-4652499. (Rabbani, Elham) (Entered: 05/09/2014)

May 9, 2014

May 9, 2014

PACER
48

RESPONSE to Motion re 43 MOTION to Reassert Motions to Dismiss by Burnett Defendants filed by All Plaintiffs. (Willett, Christopher) (Entered: 05/13/2014)

May 13, 2014

May 13, 2014

RECAP
49

ANSWER to 39 Amended Complaint and CROSSCLAIM against Sachin Dewan, Dewan Consultants PVT. LTD., Global Resources, Inc., Gulf Coast Immigration Law Center, L.L.C., Indo-Ameri Soft, L.L.C., J & M Associates of Mississippi, Inc., J & M Marine & Industrial, LLC, Law Offices of Malvern C. Burnett, A.P.C., Malvern C. Burnett, Kurella Rao, Billy R. Wilks by Signal International LLC, Signal International, Inc., Signal International Texas, L.P., Signal International Texas, G.P.. (Attachments: # 1 Answer to Exhibit 1 to Plaintiffs' Complaint)(Hangartner, Erin) Modified on 5/19/2014 (tkd, ). (Entered: 05/16/2014)

1 Answer to Exhibit 1 to Plaintiffs' Complaint

View on PACER

May 16, 2014

May 16, 2014

PACER
50

NOTICE by All Plaintiffs of Automatic Stay Against Defendants Kurella Rao and Indo-Ameri Soft, LLC (Willett, Christopher) (Entered: 05/30/2014)

May 30, 2014

May 30, 2014

RECAP
51

MOTION for Extension of Time to File Answer re 39 Amended Complaint,, by Sachin Dewan, Dewan Consultants PVT. LTD.. (Attachments: # 1 Text of Proposed Order)(Shapiro, Stephen) (Entered: 06/11/2014)

1 Text of Proposed Order

View on PACER

June 11, 2014

June 11, 2014

PACER
52

ANSWER to 39 Amended Complaint,, by Sachin Dewan, Dewan Consultants PVT. LTD..(Shapiro, Stephen) (Entered: 06/11/2014)

June 11, 2014

June 11, 2014

RECAP

ORAL ORDER granting 51 Motion for Extension of Time to Answer. Signed by Magistrate Judge Zack Hawthorn on 6/12/14. (zjh1)

June 12, 2014

June 12, 2014

PACER
53

Unopposed MOTION Entry of Consent Orders Regarding Discovery by All Plaintiffs. (Attachments: # 1 Text of Proposed Order Use of Discovery from Related Cases, # 2 Text of Proposed Order Clawback Order, # 3 Text of Proposed Order Supplemental Protective Order, # 4 Text of Proposed Order Relating to ESI Protocol, # 5 Exhibit Schedules A-E)(Willett, Christopher) (Entered: 06/18/2014)

1 Text of Proposed Order Use of Discovery from Related Cases

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2 Text of Proposed Order Clawback Order

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3 Text of Proposed Order Supplemental Protective Order

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4 Text of Proposed Order Relating to ESI Protocol

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5 Exhibit Schedules A-E

View on PACER

June 18, 2014

June 18, 2014

PACER

ORAL ORDER granting 53 Motion. This oral order will serve as a signature on the consent orders. Signed by Magistrate Judge Zack Hawthorn on 6-19-2014. (Hawthorn, Zack)

June 19, 2014

June 19, 2014

PACER
54

NOTICE of Attorney Appearance - Pro Hac Vice by Lance R Rydberg on behalf of Signal International LLC, Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc.. Filing fee $ 100, receipt number 0540-4740879. (Rydberg, Lance) (Entered: 07/11/2014)

July 11, 2014

July 11, 2014

PACER
55

ADVISORY concerning page limitations for appeals of magistrate judge decisions. Signed by Magistrate Judge Zack Hawthorn on 7/15/14. (tkd, ) (Entered: 07/16/2014)

July 15, 2014

July 15, 2014

PACER
56

ORDER denying 14 MOTION for Stay Pendent Lite and for Transfer Pursuant to First-Filed Rule, denying 31 Motion to tranfer venue. Signed by Magistrate Judge Zack Hawthorn on 7/16/14. (tkd, ) Modified on 7/17/2014 (tkd, ). (Entered: 07/17/2014)

July 16, 2014

July 16, 2014

RECAP
57

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

1 Exhibit

View on PACER

July 17, 2014

July 17, 2014

PACER
58

MOTION for Reconsideration of Magistrate's Decision re 56 Order by Signal International LLC, 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 (tkd, ). (Entered: 07/29/2014)

1 Text of Proposed Order

View on PACER

July 29, 2014

July 29, 2014

PACER
59

RESPONSE in opposition to Defendants' 57 Appeal of Magistrate Judge Decision to District Court or alternatively Objection to 56 order denying motion to transfer filed by All Plaintiffs. (Attachments: # 1 Text of Proposed Order)(Willett, Christopher) Modified on 8/1/2014 (bjc, ). (Entered: 07/31/2014)

1 Text of Proposed Order

View on PACER

July 31, 2014

July 31, 2014

PACER
60

RESPONSE in Opposition re 58 MOTION for Reconsideration of Magistrate's Decision re 56 Order filed by All Plaintiffs. (Attachments: # 1 Exhibit JPMDL Order Denying Transfer, # 2 Text of Proposed Order)(Willett, Christopher) (Entered: 08/13/2014)

1 Exhibit JPMDL Order Denying Transfer

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2 Text of Proposed Order

View on PACER

Aug. 13, 2014

Aug. 13, 2014

PACER
61

NOTICE of Attorney Appearance - Pro Hac Vice by Kevin Patrick Maney on behalf of Signal International LLC, Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc.. Filing fee $ 100, receipt number 0540-4832481. (Maney, Kevin) (Entered: 09/12/2014)

Sept. 12, 2014

Sept. 12, 2014

PACER
62

NOTICE of Attorney Appearance - Pro Hac Vice by Robert L Keller, II on behalf of Signal International LLC, Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc.. Filing fee $ 100, receipt number 0540-4832954. (Keller, Robert) (Entered: 09/12/2014)

Sept. 12, 2014

Sept. 12, 2014

PACER
63

NOTICE of Attorney Appearance - Pro Hac Vice by James L Cornblatt on behalf of Signal International LLC, Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc.. Filing fee $ 100, receipt number 0540-4832993. (Cornblatt, James) (Entered: 09/12/2014)

Sept. 12, 2014

Sept. 12, 2014

PACER
64

NOTICE of Attorney Appearance - Pro Hac Vice by Mitchell P Hasenkampf on behalf of Signal International LLC, Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc.. Filing fee $ 100, receipt number 0540-4834378. (Hasenkampf, Mitchell) (Entered: 09/15/2014)

Sept. 15, 2014

Sept. 15, 2014

PACER
65

NOTICE of Attorney Appearance - Pro Hac Vice by Lauren Masur Davis on behalf of Signal International LLC, Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc.. Filing fee $ 100, receipt number 0540-4835131. (Davis, Lauren) (Entered: 09/15/2014)

Sept. 15, 2014

Sept. 15, 2014

PACER

ORAL ORDER granting 43 Motion to Reassert 33 Motion to Dismiss and 32 Motion to Dismiss for Lack of Jurisdiction. Signed by Magistrate Judge Zack Hawthorn on 10-3-2014. (zjh1, )

Oct. 3, 2014

Oct. 3, 2014

PACER
66

ORDER denying 57 Appeal of Magistrate Judge Decision to District Court re denial of motion to transfer venue. The alternative request for an interlocutory appeal to the 5th Circuit Court of Appeals is also denied. Signed by Judge Ron Clark on 10/20/14. (tkd, ) (Entered: 10/22/2014)

Oct. 21, 2014

Oct. 21, 2014

PACER
67

ORDER denying 58 Motion for Reconsideration of Magistrate's Decision denying motion for stay pendente lite and for transfer pursuant to first filed rule. Signed by Judge Ron Clark on 10/20/14. (tkd, ) (Entered: 10/22/2014)

Oct. 21, 2014

Oct. 21, 2014

PACER
68

Unopposed MOTION for Extension of Time to File /Designate Expert Witnesses and Provide Expert Reports by All Plaintiffs. (Attachments: # 1 Text of Proposed Order)(Willett, Christopher) (Entered: 10/23/2014)

1 Text of Proposed Order

View on PACER

Oct. 23, 2014

Oct. 23, 2014

PACER

ORAL ORDER granting 68 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. (zjh1, )

Oct. 23, 2014

Oct. 23, 2014

PACER
69

ANSWER to 39 Amended Complaint,, by Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C., Malvern C. Burnett.(Cerniglia, Timothy) (Entered: 11/08/2014)

Nov. 8, 2014

Nov. 8, 2014

PACER
70

ANSWER to 49 Crossclaim by Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C., Malvern C. Burnett.(Cerniglia, Timothy) Modified on 11/10/2014 (bjc, ). (Entered: 11/08/2014)

Nov. 8, 2014

Nov. 8, 2014

RECAP
71

NOTICE of Expert Witness Disclosure by Signal International LLC, Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc. (Hangartner, Erin) Modified on 12/8/2014 (tkd, ). (Entered: 12/05/2014)

Dec. 5, 2014

Dec. 5, 2014

PACER
72

MOTION TO Extend Discovery Deadlines and the Motion Cut-Off by Signal International LLC, 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) Modified on 12/18/2014 (tkd, ). (Entered: 12/17/2014)

1 Text of Proposed Order

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2 Exhibit A

View on PACER

3 Exhibit B

View on PACER

4 Exhibit C

View on PACER

5 Exhibit D

View on PACER

6 Exhibit E

View on PACER

Dec. 17, 2014

Dec. 17, 2014

PACER
73

RESPONSE in Opposition re 72 MOTION to Extend Discovery Deadlines and the Motion Cut-Off filed by All Plaintiffs. (Attachments: # 1 Text of Proposed Order)(Willett, Christopher) (Additional attachment(s) added on 1/6/2015: # 2 Revised Proposed Order) (bjc, ). (Entered: 01/05/2015)

1 Text of Proposed Order

View on PACER

2 Revised Proposed Order

View on PACER

Jan. 5, 2015

Jan. 5, 2015

PACER
74

MOTION Exclude Testimony and Strike the Expert Report of Dr. Louise Shelley by All Plaintiffs. (Attachments: # 1 Exhibit Report of Dr. Louise Shelley, # 2 Exhibit "David" Report of Dr. Louise Shelley, # 3 Exhibit Deposition of Dr. Louise Shelley, # 4 Exhibit Order from David case, # 5 Text of Proposed Order)(Willett, Christopher) (Entered: 01/15/2015)

1 Exhibit Report of Dr. Louise Shelley

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2 Exhibit "David" Report of Dr. Louise Shelley

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3 Exhibit Deposition of Dr. Louise Shelley

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4 Exhibit Order from David case

View on PACER

5 Text of Proposed Order

View on PACER

Jan. 15, 2015

Jan. 15, 2015

PACER
75

MOTION Exclude Testimony and Strike the Expert Report of Donald H. Strobel by All Plaintiffs. (Attachments: # 1 Exhibit Report of Don H. Strobel, # 2 Exhibit "David" Report of Don H. Strobel, # 3 Text of Proposed Order)(Willett, Christopher) (Entered: 01/15/2015)

1 Exhibit Report of Don H. Strobel

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2 Exhibit "David" Report of Don H. Strobel

View on PACER

3 Text of Proposed Order

View on PACER

Jan. 15, 2015

Jan. 15, 2015

PACER
76

MOTION Exclude Testimony and Strike the Expert Report of Virginia Miles by All Plaintiffs. (Attachments: # 1 Exhibit Report of Virginia Miles, # 2 Text of Proposed Order)(Willett, Christopher) (Entered: 01/15/2015)

1 Exhibit Report of Virginia Miles

View on PACER

2 Text of Proposed Order

View on PACER

Jan. 15, 2015

Jan. 15, 2015

PACER
77

MOTION Exclude Testimony and Strike the Expert Report of Ronald L. Signorino by All Plaintiffs. (Attachments: # 1 Exhibit Report of Clyde Payne, # 2 Exhibit Report of Ronald L. Signorino, # 3 Exhibit Deposition of Ronald L. Signorino, # 4 Exhibit Correspondence to Plaintiffs, # 5 Exhibit Declaration and DOL-OSHA Interpretation, # 6 Text of Proposed Order)(Willett, Christopher) (Entered: 01/15/2015)

1 Exhibit Report of Clyde Payne

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2 Exhibit Report of Ronald L. Signorino

View on PACER

3 Exhibit Deposition of Ronald L. Signorino

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4 Exhibit Correspondence to Plaintiffs

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5 Exhibit Declaration and DOL-OSHA Interpretation

View on PACER

6 Text of Proposed Order

View on PACER

Jan. 15, 2015

Jan. 15, 2015

PACER
78

MOTION Exclude Testimony and Strike the Expert Report of Kevin Fox Gotham by All Plaintiffs. (Attachments: # 1 Exhibit Report of Kevin Fox Gotham, # 2 Exhibit Deposition of Kevin Fox Gotham, # 3 Exhibit Order from David case, # 4 Text of Proposed Order)(Willett, Christopher) (Entered: 01/15/2015)

1 Exhibit Report of Kevin Fox Gotham

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2 Exhibit Deposition of Kevin Fox Gotham

View on PACER

3 Exhibit Order from David case

View on PACER

4 Text of Proposed Order

View on PACER

Jan. 15, 2015

Jan. 15, 2015

PACER
79

MOTION Exclude Testimony and Strike the Expert Report of Ron McAlear by All Plaintiffs. (Attachments: # 1 Exhibit "David" Report of Ron McAlear, # 2 Exhibit Correspondence to Plaintiffs, # 3 Exhibit Depostion of Ron McAlear, # 4 Exhibit Report of Ron McAlear, # 5 Text of Proposed Order)(Willett, Christopher) (Entered: 01/15/2015)

1 Exhibit "David" Report of Ron McAlear

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2 Exhibit Correspondence to Plaintiffs

View on PACER

3 Exhibit Depostion of Ron McAlear

View on PACER

4 Exhibit Report of Ron McAlear

View on PACER

5 Text of Proposed Order

View on PACER

Jan. 15, 2015

Jan. 15, 2015

PACER
80

MOTION Limit Testimony of Enrique Gonzalez, III by All Plaintiffs. (Attachments: # 1 Exhibit Report of Enrique Gonzalez, # 2 Exhibit Depostion of Enrique Gonzalez, # 3 Text of Proposed Order)(Willett, Christopher) (Entered: 01/15/2015)

1 Exhibit Report of Enrique Gonzalez

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2 Exhibit Depostion of Enrique Gonzalez

View on PACER

3 Text of Proposed Order

View on PACER

Jan. 15, 2015

Jan. 15, 2015

PACER
81

MOTION to Exclude the Opinion Testimony of Clyde Payne by Signal International LLC, 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) Modified on 1/16/2015 (bjc, ). (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
82

MOTION in Limine to Exclude/Limit the Testimony of Florence Burke by Signal International LLC, 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
83

MOTION in Limine to Exclude/Limit the Testimony of Amy Mowl by Signal International LLC, 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
84

REPLY to Opposition to 72 MOTION to Extend Discovery Deadlines and the Motion Cut-Off filed by Signal International LLC, Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc.. (Hangartner, Erin) Modified on 1/16/2015 (bjc, ). (Entered: 01/16/2015)

Jan. 16, 2015

Jan. 16, 2015

PACER
85

Consent MOTION for Leave to File Substitute Document by Signal International LLC, Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc.. (Attachments: # 1 Exhibit A, # 2 Text of Proposed Order)(Hangartner, Erin) (Entered: 01/16/2015)

1 Exhibit A

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2 Text of Proposed Order

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Jan. 16, 2015

Jan. 16, 2015

PACER
86

SUR-REPLY to Reply to Response to Motion re 72 MOTION to Extend Discovery Deadlines and the Motion Cut-Off filed by All Plaintiffs. (Willett, Christopher) (Entered: 01/26/2015)

Jan. 26, 2015

Jan. 26, 2015

PACER
87

RESPONSE in Opposition re 79 MOTION Exclude Testimony and Strike the Expert Report of Ron McAlear filed by Signal International LLC, 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
88

RESPONSE in Opposition re 80 MOTION Limit Testimony of Enrique Gonzalez, III filed by Signal International LLC, 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

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3 Exhibit C - Speaking Engagements of Gonzalez

View on PACER

Jan. 29, 2015

Jan. 29, 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:

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

Plaintiff Type(s):

Private Plaintiff

Public Interest Lawyer: Yes

Filed Pro Se: No

Class Action Sought: No

Class Action Outcome: Not sought

Defendants

Billy R. Wilks, None

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

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

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

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

Kurella Rao (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

Michael Pol, 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

Outcome

Prevailing Party: Plaintiff

Nature of Relief:

Attorneys fees

Damages

Source of Relief:

Settlement

Amount Defendant Pays: $5 million

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