Case: Wilmuth v. Amazon.com, Inc.

COMPLAINT against defendant(s) Amazon.com, Inc. with JURY DEMAND (Receipt # AWAWDC-8247157) Attorney Cassandra Webster Lenning added to party Erin Combs(pty:pla), Attorney Cassandra Webster Lenning added to party Katherine Schomer(pty:pla), Attorney Cassandra Webster Lenning added to party Caroline Wilmuth(pty:pla) filed by Caroline Wilmuth, Erin Combs, Katherine Schomer. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Civil Cover Sheet, # 5 Summons)(Lenning, Cassandra) (Entered: 11/20/2023)

1 Exhibit A

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2 Exhibit B

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3 Exhibit C

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4 Civil Cover Sheet

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5 Summons

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APPLICATION OF ATTORNEY Cara E. Greene FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiffs Erin Combs, Katherine Schomer, Caroline Wilmuth (Fee Paid) Receipt No. AWAWDC-8248244 (Lenning, Cassandra) (Entered: 11/20/2023)

APPLICATION OF ATTORNEY Jahan C. Sagafi FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiffs Erin Combs, Katherine Schomer, Caroline Wilmuth (Fee Paid) Receipt No. AWAWDC-8248259 (Lenning, Cassandra) (Entered: 11/20/2023)

APPLICATION OF ATTORNEY Adam T. Klein FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiffs Erin Combs, Katherine Schomer, Caroline Wilmuth (Fee Paid) Receipt No. AWAWDC-8248271 (Lenning, Cassandra) (Entered: 11/20/2023)

APPLICATION OF ATTORNEY Menaka N. Fernando FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiffs Erin Combs, Katherine Schomer, Caroline Wilmuth (Fee Paid) Receipt No. AWAWDC-8248288 (Lenning, Cassandra) (Entered: 11/20/2023)

APPLICATION OF ATTORNEY Lindsay M. Goldbrum FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiffs Erin Combs, Katherine Schomer, Caroline Wilmuth (Fee Paid) Receipt No. AWAWDC-8248311 (Lenning, Cassandra) (Entered: 11/20/2023)

APPLICATION OF ATTORNEY Michael C. Danna FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiffs Erin Combs, Katherine Schomer, Caroline Wilmuth (Fee Paid) Receipt No. AWAWDC-8248321 (Lenning, Cassandra) (Entered: 11/20/2023)

ORDER re 4 Application for Leave to Appear Pro Hac Vice. The Court ADMITS Attorney Adam T Klein for PLAINTIFFS Erin Combs and Katherine Schomer, Caroline Wilmuth, by Clerk Ravi Subramanian. No document associated with this docket entry, text only.NOTE TO COUNSEL: Local counsel agrees to sign all filings and to be prepared to handle the matter, including the trial thereof, in the event the applicant is unable to be present on any date scheduled by the court, pursuant to LCR 83.1(d).(MG) (Entered: 11/21/2023)

ORDER re 6 Application for Leave to Appear Pro Hac Vice. The Court ADMITS Attorney Lindsay M Goldbrum for PLAINTIFFS Erin Combs, Katherine Schomer and Caroline Wilmuth, by Clerk Ravi Subramanian. No document associated with this docket entry, text only.NOTE TO COUNSEL: Local counsel agrees to sign all filings and to be prepared to handle the matter, including the trial thereof, in the event the applicant is unable to be present on any date scheduled by the court, pursuant to LCR 83.1(d).(MG) (Entered: 11/21/2023)

ORDER re 7 Application for Leave to Appear Pro Hac Vice. The Court ADMITS Attorney Michael C Danna for PLAINTIFFS Erin Combs, Katherine Schomer and Caroline Wilmuth, by Clerk Ravi Subramanian. No document associated with this docket entry, text only.NOTE TO COUNSEL: Local counsel agrees to sign all filings and to be prepared to handle the matter, including the trial thereof, in the event the applicant is unable to be present on any date scheduled by the court, pursuant to LCR 83.1(d).(MG) (Entered: 11/21/2023)

ORDER re 2 Application for Leave to Appear Pro Hac Vice. The Court ADMITS Attorney Cara E Greene for PLAINTIFFS Erin Combs and Katherine Schomer, Caroline Wilmuth, by Clerk Ravi Subramanian. No document associated with this docket entry, text only.NOTE TO COUNSEL: Local counsel agrees to sign all filings and to be prepared to handle the matter, including the trial thereof, in the event the applicant is unable to be present on any date scheduled by the court, pursuant to LCR 83.1(d).(MG) (Entered: 11/21/2023)

ORDER re 3 Application for Leave to Appear Pro Hac Vice. The Court ADMITS Attorney Jahan C Sagafi for PLAINTIFFS Erin Combs and Katherine Schomer, Caroline Wilmuth, by Clerk Ravi Subramanian. No document associated with this docket entry, text only.NOTE TO COUNSEL: Local counsel agrees to sign all filings and to be prepared to handle the matter, including the trial thereof, in the event the applicant is unable to be present on any date scheduled by the court, pursuant to LCR 83.1(d).(MG) (Entered: 11/21/2023)

Order on Application for Leave to Appear Pro Hac Vice

Notice to PHV and Local Counsel Unable to Process Application

Application for Leave to Appear Pro Hac Vice 5 by attorney Menaka N. Fernando will not be processed at this time. Attorney must first complete all requirements for PHV admission via PACER. Please contact Admissions Clerk Monique Guillebeau at 206-370-8433 or WAWD_Admissions@wawd.uscourts.gov with additional questions.(MG)

Summons(es) Electronically Issued as to defendant(s) Amazon.com Inc (MG) (Entered: 11/22/2023)

Add and Terminate Judges

Judge Jamal N Whitehead added. (MG)

WAIVER OF SERVICE of Summons upon defendant Amazon.com Inc mailed on 11/20/2023 (Schwartz, Jennifer) (Entered: 11/28/2023)

ORDER re 5 Application for Leave to Appear Pro Hac Vice. The Court ADMITS Attorney Menaka Fernando for Plaintiffs Erin Combs, Katherine Schomer,and Caroline Wilmuth, by Clerk Ravi Subramanian. No document associated with this docket entry, text only.NOTE TO COUNSEL: Local counsel agrees to sign all filings and to be prepared to handle the matter, including the trial thereof, in the event the applicant is unable to be present on any date scheduled by the court, pursuant to LCR 83.1(d).(CDA) (Entered: 11/29/2023)

Order on Application for Leave to Appear Pro Hac Vice

NOTICE of Appearance by attorney Shannon McDermott on behalf of Defendant Amazon.com Inc. (McDermott, Shannon) (Entered: 12/12/2023)

CORPORATE DISCLOSURE STATEMENT indicating no Corporate Parents and/or Affiliates. Filed pursuant to Fed.R.Civ.P 7.1(a)(1). Filed by Amazon.com Inc. (McDermott, Shannon) (Entered: 12/12/2023)

Add and Terminate Attorneys

Attorney Andrew E. Moriarty added for Amazon.com Inc, per the filing of Defendant's 16 Notice of Appearance. (KRA)

APPLICATION OF ATTORNEY Jason C. Schwartz FOR LEAVE TO APPEAR PRO HAC VICE for Defendant Amazon.com Inc (Fee Paid) Receipt No. AWAWDC-8278701 (McDermott, Shannon) (Entered: 12/14/2023)

APPLICATION OF ATTORNEY Molly T. Senger FOR LEAVE TO APPEAR PRO HAC VICE for Defendant Amazon.com Inc (Fee Paid) Receipt No. AWAWDC-8278741 (McDermott, Shannon) (Entered: 12/14/2023)

APPLICATION OF ATTORNEY Erich Alexander ("Alex") Bruhn FOR LEAVE TO APPEAR PRO HAC VICE for Defendant Amazon.com Inc (Fee Paid) Receipt No. AWAWDC-8278750 (McDermott, Shannon) (Entered: 12/14/2023)

ORDER re 18 Application for Leave to Appear Pro Hac Vice. The Court ADMITS Attorney Jason C Schwartz for Defendant Amazon.com Inc, by Clerk Ravi Subramanian. No document associated with this docket entry, text only.NOTE TO COUNSEL: Local counsel agrees to sign all filings and to be prepared to handle the matter, including the trial thereof, in the event the applicant is unable to be present on any date scheduled by the court, pursuant to LCR 83.1(d).(CDA) (Entered: 12/14/2023)

ORDER re 19 Application for Leave to Appear Pro Hac Vice. The Court ADMITS Attorney Molly Senger for Defendant Amazon.com Inc, by Clerk Ravi Subramanian. No document associated with this docket entry, text only.NOTE TO COUNSEL: Local counsel agrees to sign all filings and to be prepared to handle the matter, including the trial thereof, in the event the applicant is unable to be present on any date scheduled by the court, pursuant to LCR 83.1(d).(CDA) (Entered: 12/14/2023)

ORDER re 20 Application for Leave to Appear Pro Hac Vice. The Court ADMITS Attorney Alex Bruhn for Defendant Amazon.com Inc, by Clerk Ravi Subramanian. No document associated with this docket entry, text only.NOTE TO COUNSEL: Local counsel agrees to sign all filings and to be prepared to handle the matter, including the trial thereof, in the event the applicant is unable to be present on any date scheduled by the court, pursuant to LCR 83.1(d).(CDA) (Entered: 12/14/2023)

Order on Application for Leave to Appear Pro Hac Vice

ORDER REGARDING INITIAL DISCLOSURES AND JOINT STATUS REPORT FRCP 26(f) Conference Deadline is 2/6/2024, Initial Disclosure Deadline is 2/20/2024, Joint Status Report due by 2/27/2024. Signed by Judge Jamal N Whitehead. (GC) (Entered: 01/16/2024)

NOTICE of Filing of Consent to Join ; filed by Plaintiffs Erin Combs, Katherine Schomer, Caroline Wilmuth. (Lenning, Cassandra) (Entered: 01/17/2024)

MOTION to Dismiss and/or Strike, filed by Defendant Amazon.com Inc. Oral Argument Requested. (Attachments: # 1 Proposed Order) Noting Date 2/16/2024, (Moriarty, Andrew) (Entered: 01/19/2024)

1 Proposed Order

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APPLICATION OF ATTORNEY Jennifer Davidson FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiffs Erin Combs, Katherine Schomer, Caroline Wilmuth (Fee Paid) Receipt No. AWAWDC-8322492 (Lenning, Cassandra) (Entered: 01/23/2024)

ORDER re 27 Application for Leave to Appear Pro Hac Vice. The Court ADMITS Attorney Jennifer Davidson for PLAINTIFFS Erin Combs, Katherine Schomer and Caroline Wilmuth, by Clerk Ravi Subramanian. No document associated with this docket entry, text only.NOTE TO COUNSEL: Local counsel agrees to sign all filings and to be prepared to handle the matter, including the trial thereof, in the event the applicant is unable to be present on any date scheduled by the court, pursuant to LCR 83.1(d).(MG) (Entered: 01/24/2024)

Order on Application for Leave to Appear Pro Hac Vice

APPLICATION OF ATTORNEY Chauniqua D. Young FOR LEAVE TO APPEAR PRO HAC VICE for Plaintiffs Erin Combs, Katherine Schomer, Caroline Wilmuth (Fee Paid) Receipt No. AWAWDC-8327554 (Lenning, Cassandra) (Entered: 01/26/2024)

ORDER re 29 Application for Leave to Appear Pro Hac Vice. The Court ADMITS Attorney Chauniqua D Young for PLAINTIFFS Erin Combs, Katherine Schomer and Caroline Wilmuth, by Clerk Ravi Subramanian. No document associated with this docket entry, text only.NOTE TO COUNSEL: Local counsel agrees to sign all filings and to be prepared to handle the matter, including the trial thereof, in the event the applicant is unable to be present on any date scheduled by the court, pursuant to LCR 83.1(d).(MG) (Entered: 01/26/2024)

Order on Application for Leave to Appear Pro Hac Vice

NOTICE of Filing of Consent to Join ; filed by Plaintiffs Erin Combs, Katherine Schomer, Caroline Wilmuth. (Lenning, Cassandra) (Entered: 02/06/2024)

AMENDED COMPLAINT against defendant(s) Amazon.com Inc with JURY DEMAND filed by Caroline Wilmuth, Erin Combs, Katherine Schomer.(Lenning, Cassandra) (Entered: 02/09/2024)

AMENDED COMPLAINT *Corrected* against defendant(s) Amazon.com Inc with JURY DEMAND filed by Caroline Wilmuth, Erin Combs, Katherine Schomer.(Lenning, Cassandra) (Entered: 02/09/2024)

MOTION to Dismiss and/or Strike, filed by Defendant Amazon.com Inc. Oral Argument Requested. (Attachments: # 1 Exhibit A - First Amended Complaint Redline, # 2 Proposed Order) Noting Date 4/5/2024 3/22/2024, (Moriarty, Andrew) Modified noting date on 3/18/2024, per Order at Dkt. No. 39 (KRA). (Entered: 02/23/2024)

1 Exhibit A - First Amended Complaint Redline

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2 Proposed Order

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MINUTE ORDER: Katherine Schomer, and Erin Combs filed this action on 11/20/2023. Dkt. No. 1 . Defendant Amazon.com, Inc. filed a motion to dismiss on 1/19/2024. Dkt. No. 26 . Plaintiffs subsequently filed an amended complaint on 2/9/2024. Dkt. Nos. 32 , 33 . Then Amazon filed a second motion to dismiss, this time aimed at Plaintiffs' first amended complaint. Dkt. No. 34 . Accordingly, the Court DENIES Amazon's motion to dismiss Plaintiffs' original complaint as moot. Dkt. No. 26 . Authorized by Judge Jamal N Whitehead. (KRA)

JOINT STATUS REPORT signed by all parties. (Lenning, Cassandra) (Entered: 02/27/2024)

NOTICE of Filing of Consent to Join ; filed by Plaintiffs Erin Combs, Katherine Schomer, Caroline Wilmuth. (Lenning, Cassandra) (Entered: 03/01/2024)

Stipulated MOTION to Extend Deadlines regarding Defendant's Motion to Dismiss and/or Strike, filed by Defendant Amazon.com Inc. Noting Date 3/13/2024, (McDermott, Shannon) (Entered: 03/13/2024)

ORDER granting Parties' 38 Stipulated MOTION to Extend Deadlines regarding Defendant's Motion to Dismiss and/or Strike. Defendant's Motion to Dismiss and/or Strike is re-noted for 4/5/2024. Plaintiffs' response to the Motion is due no later than 3/21/2024. Defendant's reply is due no later than 4/5/2024. Signed by Judge Jamal N Whitehead. (KRA)

RESPONSE, by Plaintiffs Erin Combs, Katherine Schomer, Caroline Wilmuth, to 34 MOTION to Dismiss and/or Strike. Oral Argument Requested. (Lenning, Cassandra) (Entered: 03/21/2024)

NOTICE of Filing of Consent to Join ; filed by Plaintiffs Erin Combs, Katherine Schomer, Caroline Wilmuth. (Lenning, Cassandra) (Entered: 03/28/2024)

APPLICATION OF ATTORNEY Matt Gregory FOR LEAVE TO APPEAR PRO HAC VICE for Defendant Amazon.com Inc (Fee Paid) Receipt No. AWAWDC-8420326 (McDermott, Shannon) (Entered: 04/05/2024)

REPLY, filed by Defendant Amazon.com Inc, TO RESPONSE to 34 MOTION to Dismiss and/or Strike (Moriarty, Andrew) (Entered: 04/05/2024)

ORDER re 42 Application for Leave to Appear Pro Hac Vice. The Court ADMITS Attorney Matthew Gregory for DEFENDANT Amazon.com Inc, by Clerk Ravi Subramanian. No document associated with this docket entry, text only.NOTE TO COUNSEL: Local counsel agrees to sign all filings and to be prepared to handle the matter, including the trial thereof, in the event the applicant is unable to be present on any date scheduled by the court, pursuant to LCR 83.1(d).(MG) (Entered: 04/08/2024)

Order on Application for Leave to Appear Pro Hac Vice

NOTICE of Filing of Consent to Join ; filed by Plaintiffs Erin Combs, Katherine Schomer, Caroline Wilmuth. (Lenning, Cassandra) (Entered: 04/29/2024)

NOTICE of Filing of Consent to Join ; filed by Plaintiffs Erin Combs, Katherine Schomer, Caroline Wilmuth. (Lenning, Cassandra) (Entered: 05/21/2024)

MOTION to Stay or Bifurcate Class and Collective Discovery, filed by Defendant Amazon.com Inc. (Attachments: # 1 Exhibit A, # 2 Proposed Order) Noting Date 6/27/2024, (Moriarty, Andrew) (Entered: 06/06/2024)

RESPONSE, by Plaintiffs Erin Combs, Katherine Schomer, Caroline Wilmuth, to 47 MOTION to Stay or Bifurcate Class and Collective Discovery. (Lenning, Cassandra) (Entered: 06/21/2024)

Stipulated MOTION for Extension of Time for Defendant to File Reply in Support of Motion to Stay or Bifurcate Class Discovery, filed by Defendant Amazon.com Inc. Noting Date 6/26/2024, (Moriarty, Andrew) (Entered: 06/26/2024)

ORDER granting Parties' 49 Stipulated Motion for Extension of Time. The 47 Motion to Stay or Bifurcate Class and Collective Discovery is re-noted for 7/5/2024, and Amazon's reply is due no later than 7/5/2024. Signed by Judge Jamal N Whitehead.(KRA)

REPLY, filed by Defendant Amazon.com Inc, TO RESPONSE to 47 MOTION to Stay or Bifurcate Class and Collective Discovery (Moriarty, Andrew) (Entered: 07/02/2024)

NOTICE of Filing of Consent to Join ; filed by Plaintiffs Erin Combs, Katherine Schomer, Caroline Wilmuth. (Attachments: # 1 Exhibit A - Consent to Join, # 2 Exhibit B - Consent to Join)(Lenning, Cassandra) (Entered: 07/26/2024)

PROPOSED ORDER (Unsigned) Agreement Regarding Discovery of Electronically Stored Information and Proposed Order (Lenning, Cassandra) (Entered: 07/30/2024)

AGREEMENT REGARDING DISCOVERY OF ELECTRONICALLY STORED INFORMATION AND ORDER. Signed by Judge Jamal N Whitehead. (KRA)

PROPOSED ORDER (Unsigned) Stipulated Protective Order (Attachments: # 1 Redline of Model Protective Order)(Lenning, Cassandra) (Entered: 07/31/2024)

NOTICE of Filing of Consent to Join ; filed by Plaintiffs Erin Combs, Katherine Schomer, Caroline Wilmuth. (Attachments: # 1 Exhibit A - Consent to Join)(Lenning, Cassandra) (Entered: 08/12/2024)

LETTER from Plaintiffs to Court Regarding Class Discovery filed by All Plaintiffs (Lenning, Cassandra) (Entered: 08/30/2024)

RESPONSE by Defendant Amazon.com Inc re 57 Letter from Plaintiffs to Court Regarding Class Discovery (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G)(McDermott, Shannon) (Entered: 09/06/2024)

NOTICE of Change of Address/Change of Name of Attorney Shannon McDermott. Filed by Defendant Amazon.com Inc. (McDermott, Shannon) (Entered: 09/12/2024)

NOTICE of Filing of Consent to Join ; filed by Plaintiffs Erin Combs, Katherine Schomer, Caroline Wilmuth. (Attachments: # 1 Exhibit A - Consent to Join)(Lenning, Cassandra) (Entered: 10/22/2024)

APPLICATION OF ATTORNEY Lauren Blas FOR LEAVE TO APPEAR PRO HAC VICE for Defendant Amazon.com Inc (Fee Paid) Receipt No. AWAWDC-8733390 (McDermott, Shannon) (Entered: 11/25/2024)

ORDER re 61 Application for Leave to Appear Pro Hac Vice. The Court ADMITS Attorney Lauren M Blas for Defendant Amazon.com Inc, by Clerk Ravi Subramanian. No document associated with this docket entry, text only.NOTE TO COUNSEL: Local counsel agrees to sign all filings and to be prepared to handle the matter, including the trial thereof, in the event the applicant is unable to be present on any date scheduled by the court, pursuant to LCR 83.1(d).(HH) (Entered: 11/25/2024)

Order on Application for Leave to Appear Pro Hac Vice

ORDER. The Court DENIES Amazon's Motion to Dismiss and/or Strike, Dkt. No. 34 . The Court also DENIES as moot Amazon's Motion to Stay or Bifurcate Class and Collective Discovery, Dkt. No. 47 , because it asked the Court to relieve Amazon of certain discovery obligations while its Motion to Dismiss and/or Strike was pending. Signed by Judge Jamal N Whitehead. (KRA)

ORDER REGARDING INITIAL DISCLOSURES AND JOINT STATUS REPORT FRCP 26(f) Conference Deadline is 1/6/2025, Initial Disclosure Deadline is 1/21/2025, Joint Status Report due by 1/27/2025. Signed by Judge Jamal N Whitehead. (GC) (Entered: 12/16/2024)

Stipulated MOTION TO EXTEND AMAZON'S DEADLINE TO ANSWER FIRST AMENDED COMPLAINT, filed by Defendant Amazon.com Inc. Noting Date 12/20/2024, (McDermott, Shannon) (Entered: 12/20/2024)

ORDER granting Parties' 65 Stipulated Motion to Extend Amazon's Deadline to Answer First Amended Complaint. Amazon's deadline to answer the FAC is extended 45 days to 2/10/2025. Signed by Judge Jamal N Whitehead. (KRA) (Entered: 12/23/2024)

NOTICE of Opt-In Plaintiff Elvidania Caperonis's Withdrawal of Consent to Join ; filed by Plaintiffs Caroline Wilmuth, Katherine Schomer, Erin Combs. (Lenning, Cassandra) (Entered: 01/08/2025)

NOTICE of Filing of Consent to Join ; filed by Plaintiffs Caroline Wilmuth, Katherine Schomer, Erin Combs. (Attachments: # 1 Exhibit A - Consent to Join)(Lenning, Cassandra) (Entered: 01/14/2025)

JOINT STATUS REPORT signed by all parties. Filed by Plaintiffs Caroline Wilmuth, Katherine Schomer, Erin Combs.(Lenning, Cassandra) (Entered: 01/27/2025)

ANSWER to 33 Amended Complaint by Amazon.com Inc.(Moriarty, Andrew) (Entered: 02/10/2025)

NOTICE of Withdrawal of Consent to Join Collective Action of Opt-In Plaintiff Katrina Clement re 41 Notice-Other ; filed by Plaintiffs Erin Combs, Katherine Schomer, Caroline Wilmuth. (Lenning, Cassandra) (Entered: 05/30/2025)

NOTICE of Change of Address/Change of Name of Attorney Andrew E. Moriarty. Filed by Defendant Amazon.com Inc. (Moriarty, Andrew) (Entered: 06/18/2025)

MINUTE ORDER re 69 Joint Status Report. Fact Discovery Motions due by 2/15/2026. Fact Discovery completed by 3/31/2026. Plaintiffs' Class Certification-related Expert Witness Disclosures due by 5/15/2026. Rebuttal Class Certification Expert Disclosures due by 6/30/2026. Close of expert discovery, including depositions by 8/31/2026. Plaintiff's Motion for Class Certification due by 9/30/2026. Defendant's opposition to motion for class certification due by 10/30/2026. Plaintiffs' reply in support of class certification motion due by 11/4/2026. Hearing on class certification to be announced. Parties must submit proposed schedule regarding further discovery and summary judgment motions14 days following the Court's ruling on class certification. (See Order for details.) Authorized by Judge Jamal N Whitehead. (CJS) (Entered: 06/23/2025)

Compel

Declaration

Letter

1 - Order

Notice of Withdrawal of Counsel

Notice of Withdrawal of Counsel

Response to Motion

Declaration

Reply to Response to Motion

Notice of Appearance

Notice-Other