Case: Public Interest Legal Foundation v. Benson

Public Interest Legal Foundation V. Benson

COMPLAINT against Jocelyn Benson filed by Public Interest Legal Foundation (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8, # 9 Exhibit 9, # 10 Exhibit 10, # 11 Exhibit 11, # 12 Exhibit 12, # 13 Exhibit 13, # 14 Exhibit 14) (Phillips, Kaylan) (Entered: 11/03/2021)

1 Exhibit 1

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2 Exhibit 2

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3 Exhibit 3

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4 Exhibit 4

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5 Exhibit 5

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6 Exhibit 6

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7 Exhibit 7

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8 Exhibit 8

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9 Exhibit 9

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10 Exhibit 10

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11 Exhibit 11

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12 Exhibit 12

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13 Exhibit 13

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14 Exhibit 14

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PROPOSED SUMMONS to be issued re 1 (Phillips, Kaylan) (Entered: 11/03/2021)

CORPORATE DISCLOSURE STATEMENT by Public Interest Legal Foundation (Phillips, Kaylan) (Entered: 11/03/2021)

Filing Fee (Civil Case) - Credit Card Payment

FILING FEE PAID re 1 by plaintiff Public Interest Legal Foundation in the amount of $402, receipt number AMIWDC-6587015 (Phillips, Kaylan)

NOTICE that this case has been assigned Robert J. Jonker (mg) (Entered: 11/08/2021)

SUMMONS ISSUED as to defendant Jocelyn Benson (mg) (Entered: 11/08/2021)

SUMMONS returned executed; Jocelyn Benson served on 11/8/2021, answer due 11/29/2021 (Phillips, Kaylan) (Entered: 11/09/2021)

PROPOSED STIPULATION and ORDER Extending Dates by defendant Jocelyn Benson [Attorney Heather S. Meingast added to party Jocelyn Benson(pty:dft)] (Meingast, Heather) (Entered: 11/29/2021)

ORDER granting STIPULATION 7 extending dates ; signed by Chief Judge Robert J. Jonker (Chief Judge Robert J. Jonker, ymc) (Entered: 11/30/2021)

ORDER setting Rule 16 scheduling conference: Rule 16 scheduling conference is set for 2/24/2022 at 03:00 PM at 699 Federal Building, Grand Rapids, MI before Chief Judge Robert J. Jonker; status report due by 2/17/2022 ; signed by Chief Judge Robert J. Jonker (Chief Judge Robert J. Jonker, ymc) (Entered: 11/30/2021)

Order on Stipulation and Proposed Order

(NON-DOCUMENT) ATTORNEY APPEARANCE of Charlotte Davis on behalf of plaintiff Public Interest Legal Foundation as additional counsel (Davis, Charlotte)

(NON-DOCUMENT) ATTORNEY APPEARANCE of Noel H. Johnson on behalf of plaintiff Public Interest Legal Foundation as additional counsel (Johnson, Noel)

MOTION to dismiss for lack of jurisdiction, MOTION to dismiss for failure to state a claim by defendant Jocelyn Benson; (Meingast, Heather) (Entered: 12/13/2021)

BRIEF in support of MOTION to dismiss for lack of jurisdiction MOTION to dismiss for failure to state a claim 10 filed by Jocelyn Benson (Attachments: # 1 Index Exhibit List, # 2 Exhibit A. Email, # 3 Exhibit B. Email, # 4 Exhibit C. Spreadsheet Screenshot) (Meingast, Heather) (Entered: 12/13/2021)

CERTIFICATE regarding compliance with LCivR 7.1(d) re MOTION to dismiss for lack of jurisdiction MOTION to dismiss for failure to state a claim 10 filed by Jocelyn Benson (Meingast, Heather) (Entered: 12/13/2021)

CERTIFICATE of compliance re word count for Brief in Support of a Motion, 11 filed by Jocelyn Benson (Meingast, Heather) (Entered: 12/13/2021)

ANSWER to complaint, 1 with affirmative defenses by Jocelyn Benson (Meingast, Heather) (Entered: 12/13/2021)

NOTICE that this case is reassigned to District Judge Jane M. Beckering under Administrative Order No. 22-CA-01 ; Chief Judge Robert J. Jonker is no longer assigned to the case (mlc) (Entered: 01/05/2022)

RESPONSE in opposition to MOTION to dismiss for lack of jurisdiction MOTION to dismiss for failure to state a claim 10 filed by Public Interest Legal Foundation (Phillips, Kaylan) (Entered: 01/18/2022)

CERTIFICATE of compliance re word count for Response in Opposition 16 filed by Public Interest Legal Foundation (Phillips, Kaylan) (Entered: 01/18/2022)

MOTION to intervene and Brief in Support of Motion to Intervene intervenor-defendants APRI, Michigan Alliance of Retired Americans, Rise, Inc. by intervenor-defendants APRI, Michigan Alliance of Retired Americans, Rise, Inc.; (Nkwonta, Uzoma) (Entered: 01/25/2022)

CERTIFICATE regarding compliance with LCivR 7.1(d) re MOTION to intervene and Brief in Support of Motion to Intervene intervenor-defendants APRI, Michigan Alliance of Retired Americans, Rise, Inc. 18 filed by APRI, Michigan Alliance of Retired Americans, Rise, Inc. (Nkwonta, Uzoma) (Entered: 01/25/2022)

Proposed Answer to Plaintiff's Complaint for Declaratory and Injunctive Relief EXHIBIT re 18 by intervenor-defendants APRI, Michigan Alliance of Retired Americans, Rise, Inc. (Nkwonta, Uzoma) (Entered: 01/25/2022)

CORPORATE DISCLOSURE STATEMENT by APRI (Nkwonta, Uzoma) (Entered: 01/25/2022)

CORPORATE DISCLOSURE STATEMENT by Michigan Alliance of Retired Americans (Nkwonta, Uzoma) (Entered: 01/25/2022)

CORPORATE DISCLOSURE STATEMENT by Rise, Inc. (Nkwonta, Uzoma) (Entered: 01/25/2022)

REPLY to response to motion 10 to Dismiss filed by Jocelyn Benson (Grill, Erik) (Entered: 02/01/2022)

CERTIFICATE of compliance re word count for Reply to Response to Motion 24 filed by Jocelyn Benson (Grill, Erik) (Entered: 02/01/2022)

REPLY to response to motion 10 to Dismiss filed by Jocelyn Benson (Grill, Erik) (Entered: 02/02/2022)

RESPONSE in opposition to MOTION to intervene and Brief in Support of Motion to Intervene intervenor-defendants APRI, Michigan Alliance of Retired Americans, Rise, Inc. 18 filed by Jocelyn Benson (Meingast, Heather) (Entered: 02/08/2022)

RESPONSE in opposition to MOTION to intervene and Brief in Support of Motion to Intervene intervenor-defendants APRI, Michigan Alliance of Retired Americans, Rise, Inc. 18 filed by Public Interest Legal Foundation (Attachments: # 1 Exhibit A - Judicial Watch v. Logan) (Phillips, Kaylan) (Entered: 02/08/2022)

CERTIFICATE of compliance re word count for Response in Opposition, 28 filed by Public Interest Legal Foundation (Phillips, Kaylan) (Entered: 02/08/2022)

CERTIFICATE of compliance re word count for Response in Opposition 27 filed by Jocelyn Benson (Meingast, Heather) (Entered: 02/08/2022)

(NON-DOCUMENT) ATTORNEY APPEARANCE of Noah Baron on behalf of intervenor-defendants APRI, Michigan Alliance of Retired Americans, Rise, Inc. (Baron, Noah)

(NON-DOCUMENT) ATTORNEY APPEARANCE of Joel J. Ramirez on behalf of intervenor-defendants APRI, Michigan Alliance of Retired Americans, Rise, Inc. (Ramirez, Joel)

(NON-DOCUMENT) ATTORNEY APPEARANCE of Joshua L. Harris on behalf of intervenor-defendants APRI, Michigan Alliance of Retired Americans, Rise, Inc. (Harris, Joshua)

MOTION for leave to file Reply Brief in Support of Proposed Intervenor-Defendants' Motion to Intervene with Brief in Support and certificate of compliance by intervenor-defendants APRI, Michigan Alliance of Retired Americans, Rise, Inc.; (Attachments: # 1 Exhibit 1-Proposed Document, # 2 Exhibit 2- Proposed Exhibit 1 (Nkwonta, Uzoma) Modified text on 2/16/2022 (pjw). (Entered: 02/15/2022)

CERTIFICATE regarding compliance with LCivR 7.1(d) re MOTION for leave to file Reply Brief in Support of Proposed Intervenor-Defendants' Motion to Intervene 31 filed by APRI, Michigan Alliance of Retired Americans, Rise, Inc. (Nkwonta, Uzoma) (Entered: 02/16/2022)

JOINT STATUS REPORT submitted for filing by plaintiff Public Interest Legal Foundation (Phillips, Kaylan) (Entered: 02/16/2022)

NOTICE cancelling 2/24/2022 Rule 16 scheduling conference (rmw) (Entered: 02/16/2022)

OPINION AND ORDER denying motion to dismiss 10 ; granting motion for leave to file 31 ; the reply brief (ECF No. 31-1) is accepted for docketing; denying motion to intervene 18 signed by District Judge Jane M. Beckering (lep) (Entered: 08/25/2022)

REPLY to response to motion 18 (filed per 35 ) (Uzoma Nkem Nkwonta) filed by APRI, Michigan Alliance of Retired Americans, Rise, Inc. (Attachments: # 1 Exhibit 1) (mg) (Entered: 08/26/2022)

MOTION to withdraw as attorney by intervenor-defendants APRI, Michigan Alliance of Retired Americans, Rise, Inc.; (Harris, Joshua) (Entered: 09/01/2022)

PROPOSED ORDER regarding Motion to Withdraw Appearance of Counsel by intervenor-defendants APRI, Michigan Alliance of Retired Americans, Rise, Inc. (Harris, Joshua) (Entered: 09/01/2022)

ORDER setting Rule 16 scheduling conference: Rule 16 scheduling conference is set for 10/13/2022 at 11:00 AM by telephone before District Judge Jane M. Beckering; joint status report due by 10/6/2022; signed by District Judge Jane M. Beckering (rmw) (Entered: 10/03/2022)

JOINT STATUS REPORT (Phillips, Kaylan) (Entered: 10/05/2022)

(RESTRICTED ACCESS) DOCUMENT (instructions for 10/13/2022 telephonic scheduling conference) [Access to this document is available to the Court and attorney(s) for Jocelyn Benson, Public Interest Legal Foundation only] (rmw) (Entered: 10/06/2022)

MINUTES of scheduling conference by telephone held before District Judge Jane M. Beckering (Court Reporter: not recorded) (rmw) (Entered: 10/13/2022)

CASE MANAGEMENT ORDER; signed by District Judge Jane M. Beckering (rmw) (Entered: 10/13/2022)

PROOF OF SERVICE by defendant Jocelyn Benson for Response to Requests for Admissions (Grill, Erik) (Entered: 10/19/2022)

SELECTION of Mona Majzoub as facilitative mediator by plaintiff Public Interest Legal Foundation (Phillips, Kaylan) (Entered: 11/23/2022)

NOTICE of appointment of Facilitative Mediator Mona K. Majzoub; plaintiff VFM fee to be submitted by 12/7/2022 defendant VFM fee to be submitted by 12/7/2022 (kmd) (Entered: 11/30/2022)

VFM FEE RECEIVED in the amount of $25.00, check number 510161767 as to defendant Jocelyn Benson (jmw)

VFM FEE RECEIVED in the amount of $25.00, check number 1104 as to plaintiff Public Interest Legal Foundation (jmw)

PROOF OF SERVICE by plaintiff Public Interest Legal Foundation for responses to requests for admissions (Phillips, Kaylan) (Entered: 12/08/2022)

PROPOSED STIPULATION and ORDER extending deadlines in Case Management Order by plaintiff Public Interest Legal Foundation (Phillips, Kaylan) (Entered: 01/13/2023)

CHANGE OF ADDRESS by Kaylan Phillips counsel for plaintiff Public Interest Legal Foundation (Phillips, Kaylan) (Entered: 01/13/2023)

ORDER granting STIPULATION 48 ; extending certain deadlines; additional requests to extend will not be favored; signed by District Judge Jane M. Beckering (rmw) (Entered: 01/17/2023)

PROOF OF SERVICE by plaintiff Public Interest Legal Foundation for responses to requests for admissions (Phillips, Kaylan) (Entered: 01/17/2023)

PROOF OF SERVICE by defendant Jocelyn Benson for Responses to Second Requests for Admissions (Grill, Erik) (Entered: 02/08/2023)

PROPOSED STIPULATION and ORDER Extending Time for Defendant's Expert Disclosures by defendant Jocelyn Benson (Grill, Erik) (Entered: 03/01/2023)

ORDER granting STIPULATION to extend Defendant's expert witness disclosure deadline 53 ; signed by District Judge Jane M. Beckering (rmw) (Entered: 03/02/2023)

MOTION to compel by defendant Jocelyn Benson; (Grill, Erik) (Entered: 03/13/2023)

BRIEF in support of MOTION to compel 55 filed by Jocelyn Benson (Attachments: # 1 Index Exhibit List, # 2 Exhibit A. Defendant's First Interrogatories, Requests to Production Documents and Request for Admissions to Plaintiff, # 3 Exhibit B. Plaintiff's response, # 4 Exhibit C. Defendant's Second Request for Admissions to Plaintiff, # 5 Exhibit D. Plaintiff's Answers to Defendant's First Interrogatories, # 6 Exhibit E. Plaintiff's Answers to Defendant's First Requests to Produce Documents,(Please see 59 for corrected exhibit # 7 Exhibit F. Plaintiff's Answers to Defendant's Second Request for Admissions, # 8 Exhibit G. Email from Defendant's Attorney to Plaintiff's Attorney, # 9 Exhibit H. Correspondence from Plaintiff's Attorney to Defendant's Attorney, # 10 Exhibit I. Correspondence from Plaintiff's Attorney to Defendant's Attorney) (Grill, Erik) Modified text on 3/14/2023 (slk). (Entered: 03/13/2023)

CERTIFICATE regarding compliance with LCivR 7.1(d) re MOTION to compel 55 filed by Jocelyn Benson (Grill, Erik) (Entered: 03/13/2023)

CERTIFICATE of compliance re word count for Brief in Support of a Motion, 56 filed by Jocelyn Benson (Grill, Erik) Modified text on 3/14/2023 (slk). (Entered: 03/13/2023)

CORRECTED EXHIBIT E to Defendant's Motion to Compel (ECF No. 56-6) by defendant Jocelyn Benson (Grill, Erik) Modified text on 3/14/2023 (slk). (Entered: 03/14/2023)

NOTICE OF MOTION HEARING regarding Defendant's Motion to Compel 55 : motion hearing is set for 4/12/2023 at 02:00 PM by video before Magistrate Judge Sally J. Berens (jal) (Entered: 03/14/2023)

(RESTRICTED ACCESS) DOCUMENT Videoconference information for 4/12/2023 motion hearing [Access to this document is available to the Court and attorney(s) for Jocelyn Benson, Public Interest Legal Foundation only] (jal) (Entered: 03/14/2023)

MOTION for protective order by defendant Jocelyn Benson; (Meingast, Heather) (Entered: 03/14/2023)

BRIEF in support of MOTION for protective order 62 filed by Jocelyn Benson (Attachments: # 1 Index Exhibit List, # 2 Exhibit A. Notice of Deposition of Secretary of State Jocelyn Benson, # 3 Exhibit B. Email chain between attorneys, # 4 Exhibit C. Email chain between attorneys) (Meingast, Heather) (Entered: 03/14/2023)

CERTIFICATE regarding compliance with LCivR 7.1(d) re MOTION for protective order 62 filed by Jocelyn Benson (Meingast, Heather) (Entered: 03/14/2023)

CERTIFICATE of compliance re word count for Brief in Support of a Motion, 63 filed by Jocelyn Benson (Meingast, Heather) (Entered: 03/14/2023)

NOTICE OF MOTION HEARING regarding Defendant's Motion for Protective Order 62 : motion hearing is set for 4/12/2023 at 02:00 PM by video before Magistrate Judge Sally J. Berens; previously filed videoconference information 61 to remain the same (jln) (Entered: 03/14/2023)

Order Referring Motion to Magistrate Judge (Non-Document)

(NON-DOCUMENT) ORDER REFERRING MOTION to compel 55 to Magistrate Judge Sally J. Berens under 28 U.S.C. 636(b)(1)(A); signed by District Judge Jane M. Beckering (rmw)

(NON-DOCUMENT) ORDER REFERRING MOTION for protective order 62 to Magistrate Judge Sally J. Berens under 28 U.S.C. 636(b)(1)(A); signed by District Judge Jane M. Beckering (rmw)

PROOF OF SERVICE by plaintiff Public Interest Legal Foundation for Subpoena to Electronic Registration Information Center (Johnson, Noel) (Entered: 03/15/2023)

PROOF OF SERVICE by defendant Jocelyn Benson for Defendant's Expert Disclosures (Grill, Erik) (Entered: 03/15/2023)

RESPONSE in opposition to MOTION to compel 55 filed by Public Interest Legal Foundation (Attachments: # 1 Index Exhibit List, # 2 Exhibit A Email Chain, # 3 Exhibit B Declaration) (Phillips, Kaylan) Modified text on 3/28/2023 (mg). (Entered: 03/27/2023)

CERTIFICATE of compliance re word count for Response in Opposition 69 filed by Public Interest Legal Foundation (Phillips, Kaylan) (Entered: 03/27/2023)

RESPONSE in opposition to MOTION for protective order 62 filed by Public Interest Legal Foundation (Phillips, Kaylan) (Entered: 03/28/2023)

CERTIFICATE of compliance re word count for Response in Opposition 71 filed by Public Interest Legal Foundation (Phillips, Kaylan) (Entered: 03/28/2023)

(NON-DOCUMENT) ATTORNEY APPEARANCE of Joseph M. Nixon on behalf of plaintiff Public Interest Legal Foundation (Nixon, Joseph)

MINUTES of motion hearing re Defendant's Motion to Compel 55 and Defendant's Motion for Protective Order 62 held before Magistrate Judge Sally J. Berens; order to issue (Proceedings Digitally Recorded) (jln) (Entered: 04/12/2023)

ORDER granting in part, denying in part, and denying in part as moot Defendant's Motion to Compel 55 ; granting without prejudice Defendant's Motion for Protective Order 62 ; signed by Magistrate Judge Sally J. Berens (jln) (Entered: 04/12/2023)

TRANSCRIPT of Motion to Compel and for Protective Order held 04/12/2023 before Magistrate Judge Sally J. Berens; NOTE: this transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the release of transcript restriction date; after that date it may be obtained through PACER; under the Policy Regarding Transcripts the parties have 14 days within which to file a Notice of Intent to redact, and 21 days within which to file a Redaction Request; if no Transcript Redaction Request is filed, the court will assume redaction of personal identifiers is not necessary and this transcript will be made available via PACER after the release of transcript restriction set for 7/13/2023 ; redaction request due 5/5/2023 (Court Reporter-Transcriptionist: Dexter, Melinda 517-604-1732) (Entered: 04/14/2023)

PROPOSED STIPULATION and ORDER Protective Order by defendant Jocelyn Benson (Grill, Erik) (Entered: 05/03/2023)

STIPULATED PROTECTIVE ORDER granting proposed stipulated order 76 ; signed by District Judge Jane M. Beckering (rmw) (Entered: 05/03/2023)

PROPOSED STIPULATION and ORDER Extending Time for Expert Reports by Two Days by defendant Jocelyn Benson (Grill, Erik) (Entered: 05/08/2023)

ORDER granting proposed stipulated order 78 ; extending deadlines for expert reports; signed by District Judge Jane M. Beckering (rmw) (Entered: 05/08/2023)

(NON-DOCUMENT) ATTORNEY APPEARANCE of Christian Adams on behalf of plaintiff Public Interest Legal Foundation (Adams, Christian)

MOTION to Quash Subpoena and for Protective Order and to Transfer this Motion to United States District Court for the Western District of Michigan - filed by Electronic Registration Information Center, Inc. (Attachments: # 1 Certificate of Service) (Miscellaneous Filing Fee $49 paid. Receipt number ADEDC-4116459) (jfm) Modified on 4/26/2023 (nms). [Transferred from Delaware on 5/18/2023.] (Entered: 04/19/2023); modified text for transfer from case 1:23-mc-60. (ns) (Entered: 05/22/2023)

OPENING BRIEF in Support 80 MOTION to Quash Subpoena and for Protective Order and to Transfer this Motion to United States District Court for the Western District of Michigan, filed by Electronic Registration Information Center, Inc. Answering Brief/Response due date per Local Rules is 5/3/2023. (jfm) Modified on 4/26/2023 (nms). [Transferred from Delaware on 5/18/2023.] (Entered: 04/19/2023); modified text for transfer from case 1:23-mc-60. (ns) (Entered: 05/22/2023)

DECLARATION of Shane Hamlin re 80 MOTION to Quash Subpoena and for Protective Order and to Transfer this Motion to United States District Court for the Western District of Michigan, by Electronic Registration Information Center, Inc. (jfm) (Main Document 3 replaced on 4/19/2023) (jfm). (Additional attachment: # 1 added on 4/19/2023: # 1 Exhibits A-J) (jfm). Modified on 4/26/2023 (nms). [Transferred from Delaware on 5/18/2023.] (Entered: 04/19/2023) Modified text on 5/22/2023 for transfer from case 1:23-mc-60 (ns). Modified on 5/22/2023 (ns). (Entered: 05/22/2023)

DECLARATION of Robert A. Wiygul re 80 MOTION to Quash Subpoena and for Protective Order and to Transfer this Motion to United States District Court for the Western District of Michigan, by Electronic Registration Information Center, Inc. (jfm) (Main Document 4 replaced on 4/19/2023) (jfm). [Transferred from Delaware on 5/18/2023.] (Entered: 04/19/2023) (Attachment(s): # 1 Exhibits 1-13 # 2 Exhibits 14-30) Modified entry on 5/23/2023 to divide exhibits in two separate attachments due to document's size (ns). (Entered: 05/22/2023)

Disclosure Statement pursuant to Rule 7.1: No Parents or Affiliates Listed filed by Electronic Registration Information Center, Inc. (jfm) [Transferred from Delaware on 5/18/2023.] (Entered: 04/19/2023) Modified text on 5/22/2023 for transfer from case 1:23-mc-60 (ns). (Entered: 05/22/2023)

PROPOSED Order 80 MOTION to Quash Subpoena and for Protective Order and to Transfer this Motion to United States District Court for the Western District of Michigan, by Electronic Registration Information Center, Inc. (Attachments: # 1 Alternative Proposed Order)(McCullough, Bruce) Modified on 4/26/2023 (nms). [Transferred from Delaware on 5/18/2023.] (Entered: 04/19/2023) Modified text on 5/22/2023 for transfer from case 1:23-mc-60 (ns). (Entered: 05/22/2023)