Case: James v. General Mills Operations, LLC

COMPLAINT with Jury Demand filed by Conrad James. (Filing fee $402, receipt number AGANDC-12521312) (Attachments: # 1 Civil Cover Sheet)(lwb) Please visit our website at http://www.gand.uscourts.gov/commonly-used-forms to obtain Pretrial Instructions and Pretrial Associated Forms which includes the Consent To Proceed Before U.S. Magistrate form. (Entered: 04/12/2023)

1 Civil Cover Sheet

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Electronic Summons Issued as to General Mills Operations, LLC. (lwb) (Entered: 04/12/2023)

Certificate of Interested Persons and Corporate Disclosure Statement by Conrad James. (lwb) (Entered: 04/12/2023)

ANSWER to 1 COMPLAINT by General Mills Operations, LLC. Discovery ends on 10/10/2023.(Kalk, Jacqueline) Please visit our website at http://www.gand.uscourts.gov to obtain Pretrial Instructions. (Entered: 05/12/2023)

NOTICE of Appearance by Pierre-Joseph Noebes on behalf of General Mills Operations, LLC (Noebes, Pierre-Joseph) (Entered: 05/12/2023)

Certificate of Interested Persons and Corporate Disclosure Statement by General Mills Operations, LLC identifying Corporate Parent General Mills, Inc. for General Mills Operations, LLC. (Kalk, Jacqueline) (Entered: 05/12/2023)

Guidelines for Discovery and Motion Practice. Signed by Magistrate Judge Regina D Cannon on 05/15/2023. (ddm) (Entered: 05/15/2023)

JOINT PRELIMINARY REPORT AND DISCOVERY PLAN filed by General Mills Operations, LLC. (Kalk, Jacqueline) (Entered: 06/12/2023)

CERTIFICATE OF SERVICE of Defendant's Initial Disclosures by General Mills Operations, LLC.(Kalk, Jacqueline) (Entered: 06/12/2023)

CERTIFICATE OF SERVICE for Initial Disclosures by Conrad James.(Dean, Douglas) (Entered: 06/12/2023)

SCHEDULING ORDER approving the parties' 8 Joint Preliminary Report and Discovery Plan. Amendments to the pleadings submitted LATER THAN THIRTY (30) DAYS after the date of this Order will not be accepted without opposing party consent or good cause shown. The discovery deadline in this case is October 12, 2023. Any motions for summary judgment must be filed by November 13, 2023. Signed by Magistrate Judge Regina D Cannon on 06/13/2023. (ddm) (Entered: 06/13/2023)

CERTIFICATE OF SERVICE First Interrogatories & First Requests for Production by Conrad James.(Dean, Douglas) (Entered: 07/24/2023)

CERTIFICATE OF SERVICE Serving Defendant's First Interrogatories to Plaintiff by General Mills Operations, LLC.(Kalk, Jacqueline) (Entered: 07/24/2023)

CERTIFICATE OF SERVICE Serving Defendant's First Requests for Production of Documents to Plaintiff by General Mills Operations, LLC.(Kalk, Jacqueline) (Entered: 07/24/2023)

CERTIFICATE OF SERVICE Serving Defendant's Notice of Deposition of Plaintiff Conrad James by General Mills Operations, LLC.(Noebes, Pierre-Joseph) (Entered: 08/04/2023)

CERTIFICATE OF SERVICE of Defendant's Responses and Objections to Plaintiff's First Interrogatories and Requests for Production of Documents by General Mills Operations, LLC.(Kalk, Jacqueline) (Entered: 09/01/2023)

CERTIFICATE OF SERVICE by Conrad James.(Dean, Douglas) (Entered: 09/01/2023)

First MOTION for Extension of Time to Complete Discovery by Conrad James. (Attachments: # 1 Text of Proposed Order Proposed Order Extending Discovery)(Dean, Douglas) (Entered: 09/14/2023)

ORDER granting the parties' 18 Joint Motion to Extend Discovery Deadlines. Discovery in this matter shall be completed by January 10, 2024. Any motions for summary judgment must be filed by February 9, 2024, and if no motions for summary judgment are filed, the proposed Consolidated Pretrial Order will be due on that date. Signed by Magistrate Judge Regina D Cannon on 09/15/2023. (ddm) (Entered: 09/15/2023)

CERTIFICATE OF SERVICE Notice and Subpoena for Deposition of Shane Cox by Conrad James.(Dean, Douglas) (Entered: 09/29/2023)

CERTIFICATE OF SERVICE by Conrad James.(Dean, Douglas) (Entered: 11/02/2023)

Consent MOTION for Protective Order and Clawback Agreement by General Mills Operations, LLC. (Attachments: # 1 Text of Proposed Order)(Kalk, Jacqueline) (Entered: 11/03/2023)

NOTICE of Appearance by Rachel P. Kaercher on behalf of General Mills Operations, LLC (Kaercher, Rachel) (Entered: 11/03/2023)

ORDER GRANTING in part the parties' Motion for Protective Order 22 and the terms of the parties' proposed Protective Order, (Doc. 22-1), are ADOPTED IN PART and AMENDED IN PART as set forth in this Order. Signed by Magistrate Judge Regina D Cannon on 11/06/2023. (ddm) (Entered: 11/06/2023)

CERTIFICATE OF SERVICE by Conrad James.(Dean, Douglas) (Entered: 11/28/2023)

CERTIFICATE OF SERVICE of Defendant's Supplemental Initial Disclosures by General Mills Operations, LLC.(Kalk, Jacqueline) (Entered: 12/01/2023)

Joint MOTION for Extension of Time to Complete Discovery by General Mills Operations, LLC. (Attachments: # 1 Text of Proposed Order)(Kaercher, Rachel) (Entered: 01/09/2024)

ORDER granting the parties' 27 Joint Motion to Extend Discovery Deadlines. Discovery in this matter shall be completed by March 11, 2024. Any motions for summary judgment must be filed by April 10, 2024, and if no motions for summary judgment are filed, the proposed Consolidated Pretrial Order will be due on that date. Signed by Magistrate Judge Regina D Cannon on 01/10/2024. (ddm) (Entered: 01/10/2024)

CERTIFICATE OF SERVICE by Conrad James.(Dean, Douglas) (Entered: 01/25/2024)

CERTIFICATE OF SERVICE by Conrad James.(Dean, Douglas) (Entered: 02/23/2024)

CERTIFICATE OF SERVICE by Conrad James.(Dean, Douglas) (Entered: 02/26/2024)

CERTIFICATE OF SERVICE of Defendant's Responses and Objections to Plaintiff's Second Requests for Production by General Mills Operations, LLC.(Kaercher, Rachel) (Entered: 02/27/2024)

CERTIFICATE OF SERVICE of Defendant's Second Supplemental Initial Disclosures by General Mills Operations, LLC.(Kaercher, Rachel) (Entered: 03/11/2024)

MOTION for Extension of Time to Complete Discovery with Brief In Support by Conrad James. (Attachments: # 1 Exhibit 1: Oct 2023 Jarva Email Chain, # 2 Exhibit 2: Dec. 2023 Mediation Email Chain, # 3 Exhibit 3: Jan. 2024 Disco Extension Email Chain, # 4 Exhibit 4: Feb. 2024 Depo Scheduling Email Chain, # 5 Exhibit 5: Feb 2024 Two Week Extension Email, # 6 Exhibit 6: Feb 2024 30 Day Extension Email, # 7 Exhibit 7: Second RPD Supplement Promise Email, # 8 Exhibit 8: Responses to Second RPDs, # 9 Exhibit 9: Withdrawal of Consent to Extension Email, # 10 Exhibit 10: Last Day of Disco Supplement Email, # 11 Exhibit 11: Second Supp Initial Disclosures)(Dean, Douglas) (Entered: 03/11/2024)

ORDER staying discovery and all pretrial deadlines, including the summary-judgment deadline, pending the resolution of the motion to extend discovery. Defendant shall respond to Plaintiff's Motion to Extend Discovery Deadline 34 by March 25, 2024. Plaintiff may reply within 14 days of Defendant's response. Signed by Magistrate Judge Regina D Cannon on 03/13/2024. (ddm) (Entered: 03/13/2024)

RESPONSE re 34 MOTION for Extension of Time to Complete Discovery filed by General Mills Operations, LLC. (Attachments: # 1 Affidavit Declaration of Jacqueline E. Kalk, # 2 Exhibit 1 to Kalk Declaration, # 3 Exhibit 2 to Kalk Declaration, # 4 Exhibit 3 to Kalk Declaration, # 5 Exhibit 4 to Kalk Declaration, # 6 Exhibit 5 to Kalk Declaration, # 7 Exhibit 6 to Kalk Declaration, # 8 Exhibit 7 to Kalk Declaration, # 9 Exhibit 8 to Kalk Declaration, # 10 Exhibit 9 to Kalk Declaration, # 11 Exhibit 10 to Kalk Declaration, # 12 Exhibit 11 to Kalk Declaration, # 13 Exhibit 12 to Kalk Declaration, # 14 Exhibit 13 to Kalk Declaration, # 15 Exhibit 14 to Kalk Declaration, # 16 Exhibit 15 to Kalk Declaration, # 17 Exhibit 16 to Kalk Declaration, # 18 Exhibit 17 to Kalk Declaration, # 19 Exhibit 18 to Kalk Declaration, # 20 Affidavit Declaration of Rachel P. Kaercher, # 21 Exhibit 1 to Kaercher Declaration)(Kaercher, Rachel) (Entered: 03/25/2024)

REPLY to Response to Motion re 34 MOTION for Extension of Time to Complete Discovery filed by Conrad James. (Attachments: # 1 Exhibit 1: Redacted Settlement Email, # 2 Exhibit 2: Consent Withdrawal Email Chain, # 3 Exhibit 3: Jarva Transcript Excerpt)(Dean, Douglas) (Entered: 04/08/2024)

ORDER grant in part 34 Motion for Extension of Time to Complete Discovery. The discovery period will be extended by 45 days. The Scheduling Order, (Docs. 11, 19, 28), is thus REVISED as follows. Discovery shall be completed by June 10, 2024. Any motions for summary judgment must be filed by July 10, 2024, and if no motions for summary judgment are filed, the proposed Consolidated Pretrial Order will be due on that date. (rsg) (Entered: 04/26/2024)

CERTIFICATE OF SERVICE (30(b)(6) NOD, 3rd RPDs & Indv Witness NODs & Subpoenas) by Conrad James.(Dean, Douglas) (Entered: 04/30/2024)

CERTIFICATE OF SERVICE of Defendant's Objections to Plaintiff's Notice of Taking Videotaped Deposition of Defendant General Mills Operations, LLC and Plaintiff's Request for Defendant General Mills Operations, LLC to Produce Documetns, Tangible Items and Electronically Stored Information at the Deposition Pursuant to Federal Rules of Civil Procedure 26, 30(b)(6), 30(b)(5) and 34 by General Mills Operations, LLC.(Kaercher, Rachel) (Entered: 05/10/2024)

NOTICE of Appearance by Linda Carpenter on behalf of Conrad James (Carpenter, Linda) (Entered: 05/13/2024)

NOTICE of Appearance by Sharon Leah Neal on behalf of Conrad James (Neal, Sharon) (Entered: 05/13/2024)

Joint MOTION for Extension of Time to Complete Discovery by General Mills Operations, LLC. (Attachments: # 1 Text of Proposed Order)(Kalk, Jacqueline) (Entered: 05/16/2024)

ORDER granting the parties' 43 Joint Motion to Extend Discovery Deadline. Discovery in this matter shall be completed by June 14, 2024. Any motions for summary judgment must be filed by July 15, 2024, and if no motions for summary judgment are filed, the proposed Consolidated Pretrial Order will be due on that date. Signed by Magistrate Judge Regina D Cannon on 05/17/2024. (ddm) (Entered: 05/17/2024)

CERTIFICATE OF SERVICE PLAINTIFF'S AMENDCED NOTICE OF TAKING VIDEOTAPED DEPO OF D by Conrad James.(Neal, Sharon) (Entered: 05/23/2024)

CERTIFICATE OF SERVICE serving Supplemental Answers and Objections to Plaintiff's First Set of Interrogatories by General Mills Operations, LLC.(Kaercher, Rachel) (Entered: 05/30/2024)

NOTICE Of Filing by Conrad James Consolidated Discovery Statement (Carpenter, Linda) (Entered: 05/30/2024)

NOTICE Of Filing Consolidated Discovery Statement by General Mills Operations, LLC (Attachments: # 1 Exhibit A - 30(b)(6) Topics)(Kaercher, Rachel) (Entered: 05/30/2024)

CERTIFICATE OF SERVICE serving Defendant's Responses and Objections to Plaintiff's Third Requests for Production by General Mills Operations, LLC.(Kaercher, Rachel) (Entered: 05/30/2024)

NOTICE of Withdrawal of Notices of Taking Depositions re 39 Certificate of Service by Conrad James. (Carpenter, Linda) Modified on 5/31/2024 to edit docket text (ddm). (Entered: 05/31/2024)

Emergency MOTION to Stay Discovery Pending the Court's Resolution of the Parties Discovery Disputes and for an Extension of the Discovery Period with Brief In Support by Conrad James. (Attachments: # 1 Exhibit, # 2 Exhibit)(Carpenter, Linda) (Entered: 05/31/2024)

SEALED NOTICE Of Filing by Conrad James re 51 Emergency MOTION to Stay Discovery Pending the Court's Resolution of the Parties Discovery Disputes and for an Extension of the Discovery Period Exhibits (Attachments: # 1 Exhibit, # 2 Exhibit)(Carpenter, Linda) Modified on 6/3/2024 to remove the word Provisionally from the entry (ddm). (Entered: 05/31/2024)

MOTION for Leave to File Matters Under Seal re: 52 Notice of Filing, Exhibits with Brief In Support by Conrad James. (Attachments: # 1 Text of Proposed Order)(Carpenter, Linda) (Entered: 05/31/2024)

ORDER GRANTING Plaintiff's Motion to Seal 53 and DIRECTING the Clerk to PERMANENTLY SEAL the exhibits filed under Doc. 52 . Plaintiff's Motion to Stay 51 is GRANTING and this matter is hereby STAYED until the discovery disputes are resolved. As for Plaintiff's request for a discovery extension, within 10 DAYS of an order resolving the discovery disputes, the parties must file a joint statement with each side's proposed discovery timeline. The statement is not to exceed 6 pages. Signed by Magistrate Judge Regina D Cannon on 06/03/2024. (ddm) (Entered: 06/03/2024)