1
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COMPLAINT against PROTECT DEMOCRACY PROJECT, INC. ( Filing fee $ 400 receipt number 0090-5157619) filed by PROTECT DEMOCRACY PROJECT, INC.. (Attachments: # 1 Civil Cover Sheet, # 2 Exhibit, # 3 Exhibit, # 4 Exhibit, # 5 Summons USAO, # 6 Summons AG, # 7 Summons CBP, # 8 Summons DHS, # 9 Summons OMB, # 10 Summons OPM)(Barnett, Kevin) (Entered: 10/13/2017)
1 Civil Cover Sheet
View on PACER
2 Exhibit
View on PACER
3 Exhibit
View on PACER
4 Exhibit
View on PACER
5 Summons USAO
View on PACER
6 Summons AG
View on PACER
7 Summons CBP
View on PACER
8 Summons DHS
View on PACER
9 Summons OMB
View on PACER
10 Summons OPM
View on PACER
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Oct. 13, 2017
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Oct. 13, 2017
RECAP
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2
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SUMMONS (6) Issued Electronically as to CUSTOMS AND BORDER PROTECTION, DEPARTMENT OF HOMELAND SECURITY, OFFICE OF MANAGEMENT AND BUDGET, OFFICE OF PERSONNEL MANAGEMENT, U.S. Attorney and U.S. Attorney General (Attachment: # 1 Notice and Consent)(zsb) (Entered: 10/13/2017)
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Oct. 13, 2017
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Oct. 13, 2017
PACER
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3
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STANDING ORDER: The parties are hereby ORDERED to comply with the directives set out in the attached standing order. See document for details. Signed by Judge Randolph D. Moss on 10/13/17. (lcrdm3, ) (Entered: 10/13/2017)
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Oct. 13, 2017
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Oct. 13, 2017
PACER
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4
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LCvR 7.1 CERTIFICATE OF DISCLOSURE of Corporate Affiliations and Financial Interests by PROTECT DEMOCRACY PROJECT, INC. (Barnett, Kevin) (Entered: 10/13/2017)
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Oct. 13, 2017
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Oct. 13, 2017
PACER
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5
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RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed as to the United States Attorney. Date of Service Upon United States Attorney on 10/13/2017. Answer due for ALL FEDERAL DEFENDANTS by 11/12/2017. (Barnett, Kevin) (Entered: 10/13/2017)
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Oct. 13, 2017
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Oct. 13, 2017
PACER
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Case Assigned to Judge Randolph D. Moss. (zsb)
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Oct. 13, 2017
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Oct. 13, 2017
PACER
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6
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RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. CUSTOMS AND BORDER PROTECTION served on 10/16/2017; DEPARTMENT OF HOMELAND SECURITY served on 10/16/2017; OFFICE OF MANAGEMENT AND BUDGET served on 10/16/2017; OFFICE OF PERSONNEL MANAGEMENT served on 10/16/2017, RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed on United States Attorney General. Date of Service Upon United States Attorney General 10/16/2017. (Barnett, Kevin) (Entered: 10/16/2017)
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Oct. 16, 2017
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Oct. 16, 2017
PACER
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7
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NOTICE of Appearance by Scott Leeson Sroka on behalf of All Defendants (Sroka, Scott) (Entered: 11/08/2017)
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Nov. 8, 2017
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Nov. 8, 2017
PACER
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8
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NOTICE of Appearance by Nikhil Vikas Gore on behalf of PROTECT DEMOCRACY PROJECT, INC. (Gore, Nikhil) (Entered: 11/08/2017)
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Nov. 8, 2017
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Nov. 8, 2017
PACER
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9
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ANSWER to 1 Complaint by CUSTOMS AND BORDER PROTECTION, DEPARTMENT OF HOMELAND SECURITY, OFFICE OF MANAGEMENT AND BUDGET, OFFICE OF PERSONNEL MANAGEMENT.(Sroka, Scott) Modified to add link on 11/14/2017 (znmw). (Entered: 11/13/2017)
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Nov. 13, 2017
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Nov. 13, 2017
PACER
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Set/Reset Hearings: Status Conference set for 1/4/2018, at 10:15 AM, in Courtroom 21, before Judge Randolph D. Moss. (kt)
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Nov. 13, 2017
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Nov. 13, 2017
PACER
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MINUTE ORDER: The parties are hereby ORDERED to appear for a status conference on January 4, 2018, at 10:15 a.m. in Courtroom 21, to discuss the schedule for further proceedings in this matter. The parties shall confer in advance of the status conference to narrow the issues for discussion. Signed by Judge Randolph D. Moss on 11/13/17. (lcrdm3, )
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Nov. 13, 2017
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Nov. 13, 2017
PACER
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10
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NOTICE of Appearance by Jennifer H. Saperstein on behalf of PROTECT DEMOCRACY PROJECT, INC. (Saperstein, Jennifer) (Entered: 01/02/2018)
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Jan. 2, 2018
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Jan. 2, 2018
PACER
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11
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NOTICE OF WITHDRAWAL OF APPEARANCE as to PROTECT DEMOCRACY PROJECT, INC.. Attorney Kevin Travers Barnett terminated. (Barnett, Kevin) (Entered: 01/02/2018)
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Jan. 2, 2018
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Jan. 2, 2018
PACER
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Minute Entry for proceedings held before Judge Randolph D. Moss: Status Conference held on 1/4/2018. Joint Status Report due by 3/3/2018. A further Status Conference is set for 3/13/2018, at 10:00 AM, in Courtroom 21, before Judge Randolph D. Moss. (Court Reporter: Jeff Hook.) (kt)
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Jan. 4, 2018
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Jan. 4, 2018
PACER
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12
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Joint STATUS REPORT by PROTECT DEMOCRACY PROJECT, INC.. (Gore, Nikhil) (Entered: 03/02/2018)
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March 2, 2018
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March 2, 2018
PACER
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13
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STATUS REPORT by PROTECT DEMOCRACY PROJECT, INC.. (Gore, Nikhil) (Entered: 03/12/2018)
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March 12, 2018
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March 12, 2018
PACER
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Minute Entry for proceedings held before Judge Randolph D. Moss: Status Conference held on 3/13/2018. Defendant OPM shall complete its production of documents by by 4/6/2018; The remaining Defendant shall provide Plaintiffs and the Court with a production schedule by 4/13/2018. (Court Reporter: Jeff Hook.) (kt)
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March 13, 2018
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March 13, 2018
PACER
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Set/Reset Deadlines: Joint Status Report due by 4/27/2018. (kt)
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March 14, 2018
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March 14, 2018
PACER
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MINUTE ORDER: It is hereby ORDERED that the parties shall submit a joint status report on or before April 27, 2018, identifying the issues remaining in this litigation and proposing a schedule for further proceedings. Signed by Judge Randolph D. Moss on 3/14/18. (lcrdm3, )
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March 14, 2018
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March 14, 2018
PACER
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14
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STATUS REPORT and Proposed Production Schedule by CUSTOMS AND BORDER PROTECTION, DEPARTMENT OF HOMELAND SECURITY, OFFICE OF MANAGEMENT AND BUDGET, OFFICE OF PERSONNEL MANAGEMENT. (Sroka, Scott) (Entered: 04/13/2018)
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April 13, 2018
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April 13, 2018
PACER
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15
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Joint MOTION for Extension of Time to File Joint Status Report by CUSTOMS AND BORDER PROTECTION, DEPARTMENT OF HOMELAND SECURITY, OFFICE OF MANAGEMENT AND BUDGET, OFFICE OF PERSONNEL MANAGEMENT (Sroka, Scott) (Entered: 04/27/2018)
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April 27, 2018
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April 27, 2018
PACER
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Set/Reset Deadlines: Joint Status Report due by 5/4/2018. (dot)
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April 27, 2018
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April 27, 2018
PACER
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MINUTE ORDER: Upon consideration of the Joint Motion for Extension of Time 15, it is hereby ORDERED that the motion is GRANTED. The parties shall file a joint status report on or before May 4, 2018. Signed by Judge Randolph D. Moss on 4/27/18. (lcrdm3, )
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April 27, 2018
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April 27, 2018
PACER
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16
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Joint STATUS REPORT by PROTECT DEMOCRACY PROJECT, INC.. (Gore, Nikhil) (Entered: 05/04/2018)
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May 4, 2018
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May 4, 2018
PACER
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Set/Reset Hearings: Status Conference set for 5/14/2018, at 2:00 PM, in Courtroom 21, before Judge Randolph D. Moss. (kt)
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May 7, 2018
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May 7, 2018
PACER
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MINUTE ORDER: In light of the parties' Joint Status Report 16, it is hereby ORDERED that the parties shall appear for a status conference on May 14, 2018, at 2:00 p.m. in Courtroom 21. Signed by Judge Randolph D. Moss on 5/7/18. (lcrdm3, )
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May 7, 2018
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May 7, 2018
PACER
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Minute Entry for proceedings held before Judge Randolph D. Moss: Status Conference held on 5/14/2018. Document productions shall proceed as ordered on the record. A further Status Conference is set for 7/6/2018, at 12:30 PM, in Courtroom 21, before Judge Randolph D. Moss. (Court Reporter: Jeff Hook.) (kt)
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May 14, 2018
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May 14, 2018
PACER
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17
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STATUS REPORT by PROTECT DEMOCRACY PROJECT, INC.. (Gore, Nikhil) (Entered: 07/05/2018)
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July 5, 2018
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July 5, 2018
PACER
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Minute Entry for proceedings held before Judge Randolph D. Moss: Status Conference held on 7/6/2018. By 7/10/2018, Department of Homeland Security shall provide Plaintiff with search terms, as stated on the record; By 7/13/2018, but no later than 7/27/2018, the parties shall meet and confer regarding the search terms; By 7/13/2018, the Office of Personnel Management documents shall be produced, and if they are not produced the Defendants shall provide a status report with an explanation for the lack of production; Joint Status Report due by 8/17/2018. A further Status Conference is set for 9/5/2018, at 10:15 AM, in Courtroom 21, before Judge Randolph D. Moss. (Court Reporter: Jeff Hook.) (kt)
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July 6, 2018
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July 6, 2018
PACER
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18
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Unopposed MOTION for Extension of Time to File Status Report by CUSTOMS AND BORDER PROTECTION, DEPARTMENT OF HOMELAND SECURITY, OFFICE OF MANAGEMENT AND BUDGET, OFFICE OF PERSONNEL MANAGEMENT (Attachments: # 1 Text of Proposed Order)(Sroka, Scott) (Entered: 08/17/2018)
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Aug. 17, 2018
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Aug. 17, 2018
PACER
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19
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STATUS REPORT by PROTECT DEMOCRACY PROJECT, INC.. (Gore, Nikhil) (Entered: 08/17/2018)
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Aug. 17, 2018
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Aug. 17, 2018
PACER
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Set/Reset Deadlines: Joint Status Report due by 8/24/2018. (dot)
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Aug. 17, 2018
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Aug. 17, 2018
PACER
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MINUTE ORDER: In light of Defendants' Unopposed Motion for Extension of Time to File Status Report 18, it is hereby ORDERED that the motion is GRANTED. The parties shall file their joint status report on or before August 24, 2018. Signed by Judge Randolph D. Moss on 8/17/2018. (lcrdm3, )
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Aug. 17, 2018
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Aug. 17, 2018
PACER
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20
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STATUS REPORT by CUSTOMS AND BORDER PROTECTION, DEPARTMENT OF HOMELAND SECURITY, OFFICE OF MANAGEMENT AND BUDGET, OFFICE OF PERSONNEL MANAGEMENT. (Sroka, Scott) (Entered: 08/24/2018)
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Aug. 24, 2018
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Aug. 24, 2018
PACER
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21
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Supplemental STATUS REPORT by PROTECT DEMOCRACY PROJECT, INC.. (Gore, Nikhil) (Entered: 08/24/2018)
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Aug. 24, 2018
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Aug. 24, 2018
PACER
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MINUTE ORDER: Upon consideration of the parties' joint status report 20, it is hereby ORDERED that the Department of Homeland Security ("DHS") shall file a declaration on or before August 31, 2018, explaining why it cannot review and release responsive, non-exempt records at the rate proposed by Plaintiff. Signed by Judge Randolph D. Moss on 8/27/2018. (lcrdm3, )
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Aug. 27, 2018
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Aug. 27, 2018
PACER
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Set/Reset Deadlines: Department of Homeland Security ("DHS") shall file a declaration on or before 8/31/2018. (kt)
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Aug. 27, 2018
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Aug. 27, 2018
PACER
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22
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RESPONSE TO ORDER OF THE COURT re Order, Notice of Filing filed by DEPARTMENT OF HOMELAND SECURITY. (Attachments: # 1 Declaration of James V.M.L. Holzer)(Sroka, Scott) (Entered: 08/30/2018)
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Aug. 30, 2018
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Aug. 30, 2018
PACER
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Minute Entry for proceedings held before Judge Randolph D. Moss: Status Conference held on 9/5/2018. Order forthcoming. (Court Reporter Jeff Hook.) (dot)
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Sept. 5, 2018
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Sept. 5, 2018
PACER
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MINUTE ORDER: In light of the status conference held on September 5, 2018, it is hereby ORDERED that the Department of Homeland Security ("DHS") shall produce records at a minimum rate of 350 pages per month. It is further ORDERED that the parties' shall file a joint status report on or before October 5, 2018, alerting the Court to DHS's progress and proposing a briefing schedule moving forward. Signed by Judge Randolph D. Moss on 9/10/2018. (lcrdm3, )
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Sept. 10, 2018
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Sept. 10, 2018
PACER
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Set/Reset Deadlines: Joint Status Report due by 10/5/2018. (kt)
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Sept. 10, 2018
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Sept. 10, 2018
PACER
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23
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STATUS REPORT by PROTECT DEMOCRACY PROJECT, INC.. (Gore, Nikhil) (Entered: 10/05/2018)
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Oct. 5, 2018
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Oct. 5, 2018
PACER
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24
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STATUS REPORT by CUSTOMS AND BORDER PROTECTION, DEPARTMENT OF HOMELAND SECURITY, OFFICE OF MANAGEMENT AND BUDGET, OFFICE OF PERSONNEL MANAGEMENT. (Sroka, Scott) (Entered: 10/05/2018)
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Oct. 5, 2018
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Oct. 5, 2018
PACER
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Set/Reset Hearings: Status Conference set for 10/29/2018, at 10:15 AM, in Courtroom 21, before Judge Randolph D. Moss. (kt)
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Oct. 10, 2018
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Oct. 10, 2018
PACER
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MINUTE ORDER: Upon consideration of Plaintiff's status report 23, it is hereby ORDERED that the parties shall appear for a status conference on October 29, 2018, at 10:15 a.m. in Courtroom 21. Signed by Judge Randolph D. Moss on 10/10/2018. (lcrdm3, )
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Oct. 10, 2018
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Oct. 10, 2018
PACER
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25
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Supplemental STATUS REPORT by PROTECT DEMOCRACY PROJECT, INC.. (Gore, Nikhil) (Entered: 10/24/2018)
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Oct. 24, 2018
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Oct. 24, 2018
PACER
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Minute Entry for proceedings held before Judge Randolph D. Moss: Status Conference held on 10/29/2018. On or before 11/1/2018, Defendants shall respond to Plaintiffs proposed narrowing of the DHS search to taskers C & D, and OMB's voluminous search to two custodians. The parties shall continue to meet and confer. Joint Status Report due by 11/16/2018. (Court Reporter: Jeff Hook.) (kt)
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Oct. 29, 2018
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Oct. 29, 2018
PACER
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26
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STATUS REPORT by CUSTOMS AND BORDER PROTECTION, DEPARTMENT OF HOMELAND SECURITY, OFFICE OF MANAGEMENT AND BUDGET, OFFICE OF PERSONNEL MANAGEMENT. (Sroka, Scott) (Entered: 11/16/2018)
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Nov. 16, 2018
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Nov. 16, 2018
PACER
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27
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STATUS REPORT by PROTECT DEMOCRACY PROJECT, INC.. (Gore, Nikhil) (Entered: 11/16/2018)
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Nov. 16, 2018
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Nov. 16, 2018
PACER
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MINUTE ORDER: Upon consideration of the parties' status reports 26, 27, it is hereby ORDERED that the parties shall meet and confer on the issues identified in Plaintiff's status report 27 . It is further ORDERED that the parties shall file a joint status report informing the Court of the outcome of these discussions on or before December 14, 2018. Signed by Judge Randolph D. Moss on 11/25/2018. (lcrdm3, )
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Nov. 25, 2018
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Nov. 25, 2018
PACER
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Set/Reset Deadlines: Joint Status Report due by 12/14/2018. (kt)
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Nov. 26, 2018
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Nov. 26, 2018
PACER
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28
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Joint STATUS REPORT by PROTECT DEMOCRACY PROJECT, INC.. (Gore, Nikhil) (Entered: 12/14/2018)
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Dec. 14, 2018
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Dec. 14, 2018
PACER
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MINUTE ORDER: Upon consideration of the parties joint status report 28, it is hereby ORDERED that the parties shall file a further joint status report on or before January 31, 2019. Signed by Judge Randolph D. Moss on 12/16/2018. (lcrdm3, )
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Dec. 16, 2018
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Dec. 16, 2018
PACER
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Set/Reset Deadlines: Joint Status Report due by 1/31/2019. (kt)
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Dec. 17, 2018
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Dec. 17, 2018
PACER
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29
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Joint STATUS REPORT by PROTECT DEMOCRACY PROJECT, INC.. (Iraola, David) (Entered: 01/31/2019)
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Jan. 31, 2019
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Jan. 31, 2019
PACER
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MINUTE ORDER: Upon consideration of the parties' joint status report 29, it is hereby ORDERED that the parties shall file a further joint status report on or before February 15, 2019. Signed by Judge Randolph D. Moss on 2/3/2019. (lcrdm3, )
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Feb. 3, 2019
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Feb. 3, 2019
PACER
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Set/Reset Deadlines: Joint Status Report due by 2/15/2019. (kt)
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Feb. 4, 2019
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Feb. 4, 2019
PACER
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30
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Joint STATUS REPORT by PROTECT DEMOCRACY PROJECT, INC.. (Iraola, David) (Entered: 02/15/2019)
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Feb. 15, 2019
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Feb. 15, 2019
PACER
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MINUTE ORDER: Upon consideration of the parties' joint status report 30, it is hereby ORDERED that the parties shall file a further joint status report on or before March 15, 2019. It is further ORDERED that the OMB shall provide Plaintiff with information regarding the narrowed searched on or before February 22, 2019. Signed by Judge Randolph D. Moss on 2/18/2019. (lcrdm3, )
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Feb. 18, 2019
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Feb. 18, 2019
PACER
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Set/Reset Deadlines: Joint Status Report due by 3/15/2019. (kt)
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Feb. 19, 2019
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Feb. 19, 2019
PACER
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31
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Joint STATUS REPORT by PROTECT DEMOCRACY PROJECT, INC.. (Iraola, David) (Entered: 03/15/2019)
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March 15, 2019
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March 15, 2019
PACER
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Set/Reset Hearings
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March 20, 2019
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March 20, 2019
PACER
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.Order
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March 20, 2019
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March 20, 2019
PACER
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Set/Reset Hearings: Status Conference set for 4/8/2019 at 10:00 AM in Courtroom 21 before Judge Randolph D. Moss. (dot)
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March 20, 2019
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March 20, 2019
PACER
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MINUTE ORDER: In light of the parties' joint status report, it is hereby ORDERED that the parties shall appear for a status conference on April 8, 2019 at 10:00 a.m. in Courtroom 21. Signed by Judge Randolph D. Moss on 3/20/2019. (lcrdm3, )
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March 20, 2019
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March 20, 2019
PACER
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32
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Joint MOTION to Continue by PROTECT DEMOCRACY PROJECT, INC. (Iraola, David) (Entered: 04/03/2019)
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April 3, 2019
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April 3, 2019
PACER
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Notice of QC
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April 3, 2019
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April 3, 2019
PACER
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NOTICE OF ERROR re 32 Motion to Continue; emailed to DIraola@cov.com, cc'd 7 associated attorneys -- The PDF file you docketed contained errors: 1. Do Not Refile. FYI for future filings. If you are electronically filing any document, your signature must be on the document. (ztd, )
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April 3, 2019
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April 3, 2019
PACER
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MINUTE ORDER: Upon consideration of the joint motion to continue 32, it is hereby ORDERED that the motion is GRANTED. The status conference scheduled for April 8, 2019, is hereby VACATED. It is further ORDERED that the parties shall submit a further joint status report on or before May 6, 2019. Signed by Judge Randolph D. Moss on 4/4/2019. (lcrdm3, )
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April 4, 2019
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April 4, 2019
PACER
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Set/Reset Deadlines
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April 4, 2019
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April 4, 2019
PACER
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Set/Reset Deadlines: Joint Status Report due by 5/6/2018. (kt)
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April 4, 2019
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April 4, 2019
PACER
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Order on Motion to Continue
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April 4, 2019
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April 4, 2019
PACER
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33
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Joint STATUS REPORT by PROTECT DEMOCRACY PROJECT, INC.. (Iraola, David) (Entered: 05/06/2019)
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May 6, 2019
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May 6, 2019
PACER
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Set/Reset Deadlines
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May 9, 2019
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May 9, 2019
PACER
|
|
.Order
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May 9, 2019
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May 9, 2019
PACER
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MINUTE ORDER: Upon consideration of the parties' joint status report 33, it is hereby ORDERED that OMB and DHS are no longer required to make future productions in this case. It is further ORDERED that the parties shall submit a further joint status report on or before June 21, 2019. Signed by Judge Randolph D. Moss on 5/9/2019. (lcrdm3, )
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May 9, 2019
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May 9, 2019
PACER
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Set/Reset Deadlines: Joint Status Report due by 6/21/2019. (kt)
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May 9, 2019
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May 9, 2019
PACER
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34
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Status Report
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June 21, 2019
|
June 21, 2019
PACER
|
|
.Order
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June 23, 2019
|
June 23, 2019
PACER
|
|
Set/Reset Deadlines
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June 24, 2019
|
June 24, 2019
PACER
|
35
|
Status Report
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July 31, 2019
|
July 31, 2019
PACER
|
|
.Order
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Aug. 5, 2019
|
Aug. 5, 2019
PACER
|
|
Set/Reset Deadlines
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Aug. 6, 2019
|
Aug. 6, 2019
PACER
|
36
|
Status Report
|
Sept. 6, 2019
|
Sept. 6, 2019
PACER
|
|
Set/Reset Deadlines
|
Sept. 6, 2019
|
Sept. 6, 2019
PACER
|
|
.Order
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Sept. 6, 2019
|
Sept. 6, 2019
PACER
|
37
|
Status Report
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Nov. 22, 2019
|
Nov. 22, 2019
PACER
|
|
~Util - Set/Reset Deadlines
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Nov. 25, 2019
|
Nov. 25, 2019
PACER
|
|
.Order
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Nov. 25, 2019
|
Nov. 25, 2019
PACER
|
38
|
Status Report
|
Jan. 6, 2020
|
Jan. 6, 2020
PACER
|
|
Set/Reset Deadlines
|
Jan. 6, 2020
|
Jan. 6, 2020
PACER
|
|
.Order
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Jan. 6, 2020
|
Jan. 6, 2020
PACER
|
39
|
Notice of Substitution of Counsel
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Feb. 12, 2020
|
Feb. 12, 2020
PACER
|
40
|
Status Report
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Feb. 29, 2020
|
Feb. 29, 2020
PACER
|
|
Set/Reset Deadlines
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March 5, 2020
|
March 5, 2020
PACER
|
|
.Order
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March 5, 2020
|
March 5, 2020
PACER
|
|
~Util - Set/Reset Deadlines
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March 5, 2020
|
March 5, 2020
PACER
|
41
|
Status Report
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April 1, 2020
|
April 1, 2020
PACER
|
|
.Order
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April 2, 2020
|
April 2, 2020
PACER
|