Case: Kloosterman v. Metropolitan Hospital

COMPLAINT with jury demand against All Defendants filed by Valerie Kloosterman (Attachments: # 1 Summons, # 2 Summons, # 3 Summons, # 4 Summons, # 5 Summons, # 6 Summons, # 7 (STRICKEN AND REMOVED) Exhibit A, # 8 (STRICKEN AND REMOVED) Exhibit B, # 9 (STRICKEN AND REMOVED) Exhibit C, # 10 (STRICKEN AND REMOVED) Exhibit D, # 11 Exhibit E, # 12 (STRICKEN AND REMOVED) Exhibit F, # 13 Exhibit G, # 14 (STRICKEN AND REMOVED) Exhibit H, # 15 Exhibit I) (Wierenga, James) Modified text on 10/12/2022 (slk). Modified text on 10/25/2022 per order 6 (jlg) (Entered: 10/11/2022)

1 Summons

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2 Summons

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3 Summons

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4 Summons

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5 Summons

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6 Summons

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7 Exhibit A

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8 Exhibit B

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9 Exhibit C

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10 Exhibit D

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11 Exhibit E

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12 Exhibit F

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13 Exhibit G

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14 Exhibit H

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15 Exhibit I

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Filing Fee (Civil Case) - Credit Card Payment

FILING FEE PAID re 1 by plaintiff Valerie Kloosterman in the amount of $402, receipt number AMIWDC-6868017 (Wierenga, James)

NOTICE that this case has been assigned Jane M. Beckering (slk) (Entered: 10/12/2022)

SUMMONS ISSUED as to defendants Rhae-Ann Booker, Marla Cole, Metropolitan Hospital, Rakesh Pai, Thomas Pierce, Catherine Smith (slk) (Entered: 10/12/2022)

(NON-DOCUMENT) ATTORNEY APPEARANCE of Jordan E. Pratt on behalf of plaintiff Valerie Kloosterman (Pratt, Jordan)

(NON-DOCUMENT) ATTORNEY APPEARANCE of Kayla Toney on behalf of plaintiff Valerie Kloosterman (Toney, Kayla)

(NON-DOCUMENT) ATTORNEY APPEARANCE of David Jonathan Hacker on behalf of plaintiff Valerie Kloosterman (Hacker, David)

Attorney Appearance

NOTICE re 1 Errata re Complaint Exhibits by plaintiff Valerie Kloosterman (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit F, # 6 Exhibit H) (Toney, Kayla) (Entered: 10/24/2022)

MOTION to amend/correct 1 Complaint Exhibits by plaintiff Valerie Kloosterman; (Attachments: # 1 Exhibit A) (Toney, Kayla) (Entered: 10/24/2022)

1 Exhibit A

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ORDER granting motion to strike and remove certain exhibits 5 ; the Clerk of Court is directed to strike and remove certain exhibits to the Complaint; signed by District Judge Jane M. Beckering (rmw) (Entered: 10/24/2022)

(NON-DOCUMENT) ATTORNEY APPEARANCE of Larry R. Jensen on behalf of defendants Rhae-Ann Booker, Marla Cole, Metropolitan Hospital, Rakesh Pai, Thomas Pierce, Catherine Smith (Jensen, Larry)

(NON-DOCUMENT) ATTORNEY APPEARANCE of Jonathon A. Rabin on behalf of defendants Rhae-Ann Booker, Marla Cole, Metropolitan Hospital, Rakesh Pai, Thomas Pierce, Catherine Smith (Rabin, Jonathon)

Attorney Appearance

(NON-DOCUMENT) ATTORNEY APPEARANCE of Jessica Biondo on behalf of defendants Rhae-Ann Booker, Marla Cole, Metropolitan Hospital, Rakesh Pai, Thomas Pierce, Catherine Smith (Biondo, Jessica)

Attorney Appearance

WAIVER OF SERVICE returned executed by Valerie Kloosterman as to Marla Cole waiver sent on 11/8/2022, answer due 1/9/2023 (Pratt, Jordan) (Entered: 11/08/2022)

WAIVER OF SERVICE returned executed by Valerie Kloosterman as to Rakesh Pai waiver sent on 11/8/2022, answer due 1/9/2023 (Pratt, Jordan) (Entered: 11/08/2022)

WAIVER OF SERVICE returned executed by Valerie Kloosterman as to Rhae-Ann Booker waiver sent on 11/8/2022, answer due 1/9/2023 (Pratt, Jordan) (Entered: 11/08/2022)

WAIVER OF SERVICE returned executed by Valerie Kloosterman as to Thomas Pierce waiver sent on 11/8/2022, answer due 1/9/2023 (Pratt, Jordan) (Entered: 11/08/2022)

WAIVER OF SERVICE returned executed by Valerie Kloosterman as to Catherine Smith waiver sent on 11/8/2022, answer due 1/9/2023 (Pratt, Jordan) (Entered: 11/08/2022)

STIPULATION and PROPOSED ORDER by plaintiff Valerie Kloosterman (Attachments: # 1 Exhibit A) (Pratt, Jordan) (Entered: 11/08/2022)

ORDER granting STIPULATION 12 ; Defendant Metropolitan Hospital must file and serve its responsive pleading on or before 1/9/2023; signed by District Judge Jane M. Beckering (rmw) (Entered: 11/09/2022)

(NON-DOCUMENT) ATTORNEY APPEARANCE of Andrew W. Gould on behalf of plaintiff Valerie Kloosterman (Gould, Andrew)

Attorney Appearance

(NON-DOCUMENT) ATTORNEY APPEARANCE of Michael Berry on behalf of plaintiff Valerie Kloosterman (Berry, Michael)

Attorney Appearance

MOTION to dismiss for failure to state a claim, MOTION to dismiss for lack of jurisdiction by defendants Rhae-Ann Booker, Marla Cole, Rakesh Pai, Thomas Pierce, Catherine Smith; (Rabin, Jonathon) (Entered: 01/09/2023)

BRIEF in support of MOTION to dismiss for failure to state a claim MOTION to dismiss for lack of jurisdiction 14 filed by Rhae-Ann Booker, Marla Cole, Rakesh Pai, Thomas Pierce, Catherine Smith (Rabin, Jonathon) (Entered: 01/09/2023)

MOTION to dismiss for failure to state a claim, MOTION to dismiss for lack of jurisdiction by defendant Metropolitan Hospital; (Rabin, Jonathon) (Entered: 01/09/2023)

BRIEF in support of MOTION to dismiss for failure to state a claim MOTION to dismiss for lack of jurisdiction 16 filed by Metropolitan Hospital (Attachments: # 1 Exhibit 1- Policy RM-27, # 2 Exhibit 2- Patient Policy Flyer, # 3 Exhibit 3- EEOC Charge) (Rabin, Jonathon) (Entered: 01/09/2023)

PROPOSED ORDER regarding allowing defendants Pai, Booker, Cole, Pierce, and Smith to file amended motion and brief in support of motion to dismiss Plaintiff's Complaint by defendants Rhae-Ann Booker, Marla Cole, Metropolitan Hospital, Rakesh Pai, Thomas Pierce, Catherine Smith (Rabin, Jonathon) Modified text on 1/17/2023 (slk). (Entered: 01/13/2023)

ORDER denying without prejudice stipulated proposed order 18 ; signed by District Judge Jane M. Beckering (rmw) (Entered: 01/17/2023)

CHANGE OF ADDRESS by David Joshua Williams counsel for plaintiff Valerie Kloosterman (Williams, David) (Entered: 01/17/2023)

Attorney Appearance

(NON-DOCUMENT) ATTORNEY APPEARANCE of David Joshua Williams on behalf of plaintiff Valerie Kloosterman (Williams, David)

PROPOSED ORDER regarding Amended Motion and Brief in Support of Motion to Dismiss by defendants Rhae-Ann Booker, Marla Cole, Rakesh Pai, Thomas Pierce, Catherine Smith (Attachments: # 1 Exhibit A, Amended Motion, # 2 Exhibit B, Amended Brief) (Rabin, Jonathon) (Entered: 01/18/2023)

1 Exhibit A, Amended Motion

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2 Exhibit B, Amended Brief

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ORDER granting to an extent proposed stipulated order 21 ; consistent with the directive in this Order, the Clerk of Court shall accept for filing the proposed amended motion (ECF No. 21-1) and brief (ECF No. 21-2); Plaintiff's responses to motion 16 and the amended motion due not later than 2/16/2023; dismissing as moot motion to dismiss 14 ; signed by District Judge Jane M. Beckering (rmw) (Entered: 01/19/2023)

AMENDED MOTION to dismiss (filed per order 22 ) by defendants Rhae-Ann Booker, Marla Cole, Rakesh Pai, Thomas Pierce, Catherine Smith; (jlg) (Entered: 01/20/2023)

BRIEF in support of AMENDED MOTION to dismiss (filed per order 22 ) 23 filed by Rhae-Ann Booker, Marla Cole, Rakesh Pai, Thomas Pierce, Catherine Smith (jlg) (Entered: 01/20/2023)

ORDER that Defendant Metropolitan Hospital file a corporate disclosure statement within 7 days; signed by District Judge Jane M. Beckering (rmw) (Entered: 01/20/2023)

MOTION to stay discovery by defendants Rhae-Ann Booker, Marla Cole, Metropolitan Hospital, Rakesh Pai, Thomas Pierce, Catherine Smith; (Rabin, Jonathon) (Entered: 01/23/2023)

BRIEF in support of MOTION to stay discovery 26 filed by Rhae-Ann Booker, Marla Cole, Metropolitan Hospital, Rakesh Pai, Thomas Pierce, Catherine Smith (Rabin, Jonathon) (Entered: 01/23/2023)

CERTIFICATE regarding compliance with LCivR 7.1(d) re MOTION to stay discovery 26 filed by Rhae-Ann Booker, Marla Cole, Metropolitan Hospital, Rakesh Pai, Thomas Pierce, Catherine Smith (Rabin, Jonathon) (Entered: 01/23/2023)

CORPORATE DISCLOSURE STATEMENT by Metropolitan Hospital identifying Corporate Parent UM Health, Other Affiliate Board of Regents of the University of Michigan for Metropolitan Hospital (Rabin, Jonathon) (Entered: 01/27/2023)

AMENDED COMPLAINT against All Defendants filed by Valerie Kloosterman (Pratt, Jordan) (Entered: 01/30/2023)

(NON-DOCUMENT) ATTORNEY APPEARANCE of Courtney Jones on behalf of plaintiff Valerie Kloosterman (Jones, Courtney)

Attorney Appearance

NOTICE to attorney Jordan Pratt regarding recent filing 30 (slk) (Entered: 01/31/2023)

CORRECTED FIRST AMENDED COMPLAINT against All Defendants filed by Valerie Kloosterman (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I) (Pratt, Jordan) Modified text on 2/1/2023 (slk). (Entered: 01/31/2023)

1 Exhibit A

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2 Exhibit B

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3 Exhibit C

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4 Exhibit D

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5 Exhibit E

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6 Exhibit F

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7 Exhibit G

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8 Exhibit H

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9 Exhibit I

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Attorney Appearance

(NON-DOCUMENT) ATTORNEY APPEARANCE of Roger Byron on behalf of plaintiff Valerie Kloosterman (Byron, Roger)

ORDER dismissing as moot motions to dismiss 16 and 23 ; dismissing as moot motion to stay 26 ; signed by District Judge Jane M. Beckering (lep) (Entered: 02/01/2023)

Order on Motion to Dismiss/Lack of Jurisdiction AND Order on Motion to Dismiss for Failure to State a Claim AND Order on Motion to Dismiss AND Order on Motion to Stay

MOTION to dismiss for failure to state a claim, MOTION to dismiss for lack of jurisdiction by defendants Rhae-Ann Booker, Marla Cole, Rakesh Pai, Thomas Pierce, Catherine Smith; (Rabin, Jonathon) (Entered: 02/20/2023)

BRIEF in support of MOTION to dismiss for failure to state a claim MOTION to dismiss for lack of jurisdiction 34 filed by Rhae-Ann Booker, Marla Cole, Rakesh Pai, Thomas Pierce, Catherine Smith (Rabin, Jonathon) (Entered: 02/20/2023)

MOTION to dismiss for failure to state a claim, MOTION to dismiss for lack of jurisdiction by defendant Metropolitan Hospital; (Rabin, Jonathon) (Entered: 02/20/2023)

BRIEF in support of MOTION to dismiss for failure to state a claim MOTION to dismiss for lack of jurisdiction 36 filed by Metropolitan Hospital (Attachments: # 1 Exhibit 1- Policy RM-27, # 2 Exhibit 2- Patient Policy Flyer, # 3 Exhibit 3- EEOC Charge) (Rabin, Jonathon) (Entered: 02/20/2023)

1 Exhibit 1- Policy RM-27

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2 Exhibit 2- Patient Policy Flyer

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3 Exhibit 3- EEOC Charge

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MOTION for protective order by defendants Rhae-Ann Booker, Marla Cole, Metropolitan Hospital, Rakesh Pai, Thomas Pierce, Catherine Smith; (Rabin, Jonathon) (Entered: 02/22/2023)

BRIEF in support of MOTION for protective order 38 filed by Rhae-Ann Booker, Marla Cole, Metropolitan Hospital, Rakesh Pai, Thomas Pierce, Catherine Smith (Attachments: # 1 Exhibit 1 02.20.2023 Email from A. Gould) (Rabin, Jonathon) Modified text on 2/22/2023 (slk). (Entered: 02/22/2023)

1 Exhibit 1 02.20.2023 Email from A. Gould

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CERTIFICATE regarding compliance with LCivR 7.1(d) re MOTION for protective order 38 filed by Rhae-Ann Booker, Marla Cole, Metropolitan Hospital, Rakesh Pai, Thomas Pierce, Catherine Smith (Rabin, Jonathon) (Entered: 02/22/2023)

STIPULATION and PROPOSED ORDER to Extend Briefing Schedule for Defendants' Motions to Dismiss by plaintiff Valerie Kloosterman (Attachments: # 1 Proposed Order Granting Parties' Stipulation to Extend Briefing Schedule for Defendants' Motions to Dismiss) (Williams, David) (Entered: 03/06/2023)

1 Proposed Order Granting Parties' Stipulation to Extend Briefing Schedule fo

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ORDER granting STIPULATION 41 ; Plaintiff's responses to motions 34, 36 due no later than 4/18/2023; Defendants' replies due no later than 5/11/2023; signed by District Judge Jane M. Beckering (rmw) (Entered: 03/07/2023)

ORDER granting motion to stay discovery 38 ; signed by District Judge Jane M. Beckering (rmw) (Entered: 03/09/2023)

Attorney Appearance

(NON-DOCUMENT) ATTORNEY APPEARANCE of Kathryn Elizabeth Jones on behalf of defendants Rhae-Ann Booker, Marla Cole, Metropolitan Hospital, Rakesh Pai, Thomas Pierce, Catherine Smith (Jones, Kathryn)

STIPULATION and PROPOSED ORDER Regarding extension of briefing schedule for Defendants' motions to dismiss by plaintiff Valerie Kloosterman (Attachments: # 1 Proposed Order Granting Parties Stipulation to Extend Briefing Schedule for Defendants' Motions to Dismiss) (Williams, David) Modified text on 4/6/2023 (slk). (Entered: 04/05/2023)

1 Proposed Order Granting Parties Stipulation to Extend Briefing Schedule for Defe

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ORDER denying without prejudice STIPULATION 44 ; signed by District Judge Jane M. Beckering (rmw) (Entered: 04/06/2023)

STIPULATION and PROPOSED ORDER regarding Extension of Briefing Schedule for Defendants' Motions to Dismiss by plaintiff Valerie Kloosterman (Attachments: # 1 Proposed Order Granting Amended Stipulation with Good Cause to Extend Briefing Schedule for Defendants' Motions to Dismiss) (Williams, David) (Entered: 04/10/2023)

1 Proposed Order Granting Amended Stipulation with Good Cause to Extend Briefing S

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ORDER granting STIPULATION 46 ; Plaintiff's responses to motions 34, 36 due no later than 5/9/2023; Defendants' replies due no later than 6/1/2023; signed by District Judge Jane M. Beckering (rmw) (Entered: 04/11/2023)

NOTICE OF WITHDRAWAL of Jordan E. Pratt as counsel by plaintiff Valerie Kloosterman (Wierenga, James) Modified text on 4/24/2023 (slk). (Entered: 04/24/2023)

RESPONSE in opposition to MOTION to dismiss for failure to state a claim MOTION to dismiss for lack of jurisdiction 36 filed by Valerie Kloosterman (Wierenga, James) (Entered: 05/09/2023)

MOTION to amend/correct the Corrected First Amended Complaint by plaintiff Valerie Kloosterman; (Wierenga, James) (Entered: 05/09/2023)

CORRECTED MOTION to amend/correct the Corrected First Amended Complaint by plaintiff Valerie Kloosterman; (Attachments: # 1 Exhibit 1, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F, # 8 Exhibit G, # 9 Exhibit H, # 10 Exhibit I) (Wierenga, James) Modified text on 5/10/2023 - this document replaces 50 (slk). (Entered: 05/09/2023)

1 Exhibit 1

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2 Exhibit A

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3 Exhibit B

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4 Exhibit C

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5 Exhibit D

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6 Exhibit E

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7 Exhibit F

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8 Exhibit G

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9 Exhibit H

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10 Exhibit I

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BRIEF in support of MOTION to amend/correct the Corrected First Amended Complaint 51 filed by Valerie Kloosterman (Wierenga, James) (Entered: 05/09/2023)

PROPOSED ORDER regarding Plaintiff's Motion for Leave to Amend the Corrected First Amended Complaint by plaintiff Valerie Kloosterman (Wierenga, James) (Entered: 05/09/2023)

CERTIFICATE regarding compliance with LCivR 7.1(d) re MOTION to amend/correct the Corrected First Amended Complaint 51 filed by Valerie Kloosterman (Wierenga, James) (Entered: 05/09/2023)

RESPONSE in opposition to MOTION to dismiss for failure to state a claim MOTION to dismiss for lack of jurisdiction 34 filed by Valerie Kloosterman (Wierenga, James) (Entered: 05/09/2023)

RESPONSE in opposition to MOTION to amend/correct the Corrected First Amended Complaint 51 filed by Rhae-Ann Booker, Marla Cole, Metropolitan Hospital, Rakesh Pai, Thomas Pierce, Catherine Smith (Rabin, Jonathon) (Entered: 05/23/2023)

MOTION for leave to file Reply Brief in support of Motion to amend/correct by plaintiff Valerie Kloosterman; (Attachments: # 1 Proposed Document Reply Brief in support of Motion to amend/correct, # 2 Proposed Order) (Toney, Kayla) (Entered: 05/25/2023)

1 Proposed Document Reply Brief in support of Motion to amend/correct

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2 Proposed Order

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ORDER regarding Motion for leave to file reply 57 and certificate of concurrence; the motion is denied without prejudice to refile; signed by District Judge Jane M. Beckering (rmw) (Entered: 05/26/2023)

MOTION for leave to file Reply Brief in support of Motion to amend/correct by plaintiff Valerie Kloosterman; (Attachments: # 1 Proposed Document Reply Brief in support of Motion to amend/correct, # 2 Proposed Order) (Toney, Kayla) (Entered: 05/26/2023)

1 Proposed Document Reply Brief in support of Motion to amend/correct

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2 Proposed Order

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CERTIFICATE regarding compliance with LCivR 7.1(d) re MOTION for leave to file Reply Brief in support of Motion to amend/correct 59 filed by Valerie Kloosterman (Toney, Kayla) (Entered: 05/26/2023)

RESPONSE in opposition to MOTION for leave to file Reply Brief in support of Motion to amend/correct 59 filed by Rhae-Ann Booker, Marla Cole, Metropolitan Hospital, Rakesh Pai, Thomas Pierce, Catherine Smith (Rabin, Jonathon) (Entered: 05/26/2023)

BRIEF IN SUPPORT OF RESPONSE in opposition to MOTION for leave to file Reply Brief in support of Motion to amend/correct 61 ; regarding document 59 filed by Rhae-Ann Booker, Marla Cole, Metropolitan Hospital, Rakesh Pai, Thomas Pierce, Catherine Smith (Rabin, Jonathon) Modified text on 5/30/2023 (slk). (Entered: 05/26/2023)

NOTICE Of withdrawal of Courtney Jones as counsel by plaintiff Valerie Kloosterman (Williams, David) Modified text on 6/1/2023 (slk). (Entered: 05/31/2023)

REPLY to response to motion 34 to Dismiss filed by Rhae-Ann Booker, Marla Cole, Rakesh Pai, Thomas Pierce, Catherine Smith (Rabin, Jonathon) (Entered: 06/01/2023)

REPLY to response to motion 36 to Dismiss filed by Metropolitan Hospital (Rabin, Jonathon) (Entered: 06/01/2023)

NOTICE of Supplemental Authority for 55, 49, regarding motions 34 and 36 by plaintiff Valerie Kloosterman (Attachments: # 1 Exhibit A, # 2 Exhibit B) (Toney, Kayla) Modified text on 7/6/2023 (slk). (Entered: 07/06/2023)

1 Exhibit A

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2 Exhibit B

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RESPONSE TO 66 Plaintiff's Notice of Supplemental Authority filed by defendants Rhae-Ann Booker, Marla Cole, Metropolitan Hospital, Rakesh Pai, Thomas Pierce, Catherine Smith (Jensen, Larry) (Entered: 07/10/2023)

OPINION AND ORDER granting in part and denying in part motions to dismiss 34 and 36 ; granting in part and denying in part motion to amend/correct 50, corrected by 51 ; Plaintiff shall file a second amended complaint within 21 days; denying as moot motion for leave to file 59 ; signed by District Judge Jane M. Beckering (lep) (Entered: 09/20/2023)

SECOND AMENDED COMPLAINT against All Defendants filed by Valerie Kloosterman (Attachments: # 1 Exhibit A - EEOC Charge, # 2 Exhibit B - Amended Charge, # 3 Exhibit C - Determination and Notice of Rights, # 4 Exhibit D - Employment Agreement, # 5 Exhibit E - Performance Reviews, # 6 Exhibit F - Termination Notice, # 7 Exhibit G - Eml from Amy DeGood, # 8 Exhibit H - Reasons for Termination, # 9 Exhibit I - CMDA Statement on Transgender Identification) (Wierenga, James) (Entered: 10/11/2023)

1 Exhibit A - EEOC Charge

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2 Exhibit B - Amended Charge

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3 Exhibit C - Determination and Notice of Rights

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4 Exhibit D - Employment Agreement

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5 Exhibit E - Performance Reviews

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6 Exhibit F - Termination Notice

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7 Exhibit G - Eml from Amy DeGood

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8 Exhibit H - Reasons for Termination

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9 Exhibit I - CMDA Statement on Transgender Identification

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NOTICE Of Withdrawal As Counsel by plaintiff Valerie Kloosterman (Gould, Andrew) (Entered: 10/20/2023)

ANSWER to Amended Complaint,, 69 with affirmative defenses by Rhae-Ann Booker, Marla Cole, Metropolitan Hospital, Rakesh Pai, Thomas Pierce, Catherine Smith (Rabin, Jonathon) (Entered: 10/25/2023)

ORDER setting Rule 16 scheduling conference: Rule 16 scheduling conference is set for 11/21/2023 at 10:00 AM by telephone before District Judge Jane M. Beckering; joint status report due by 11/14/2023; signed by District Judge Jane M. Beckering (rmw) (Entered: 10/27/2023)

MOTION for summary judgment to Compel Arbitration by defendants Rhae-Ann Booker, Marla Cole, Metropolitan Hospital, Rakesh Pai, Thomas Pierce, Catherine Smith; (Rabin, Jonathon) (Entered: 11/02/2023)

BRIEF in support of MOTION for summary judgment to Compel Arbitration 73 with certificate of compliance filed by Rhae-Ann Booker, Marla Cole, Metropolitan Hospital, Rakesh Pai, Thomas Pierce, Catherine Smith (Attachments: # 1 Exhibit A) (Rabin, Jonathon) Modified text on 11/3/2023 (mlc) (Entered: 11/02/2023)

1 Exhibit A

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NOTICE adjourning without date 11/21/2023 Rule 16 scheduling conference (rmw) (Entered: 11/03/2023)

RESPONSE in opposition to MOTION for summary judgment to Compel Arbitration 73 filed by Valerie Kloosterman (Attachments: # 1 Affidavit Kloosterman Declaration, # 2 Exhibit A - Employment Agr., # 3 Exhibit B - Amendment #1 to Employment Agr, # 4 Exhibit C - Amendment to Employment Agr, # 5 Exhibit D - Notice of Termination of Agr, # 6 Affidavit Atty Declaration for MSJ, # 7 Exhibit E - Email communications) (Wierenga, James) (Entered: 11/30/2023)

1 Affidavit Kloosterman Declaration

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2 Exhibit A - Employment Agr.

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3 Exhibit B - Amendment #1 to Employment Agr

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4 Exhibit C - Amendment to Employment Agr

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5 Exhibit D - Notice of Termination of Agr

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6 Affidavit Atty Declaration for MSJ

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7 Exhibit E - Email communications

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