Case: Zou v. Grasso

Zou v. Ono

Zou et al. v. Grasso et al.

Zou et al. v. Ono et al.

Zou et al. v. Grasso et al.

Zou et al. v. Grasso et al.

Zou et al. v. Grasso et al.

Zou et al. v. Grasso et al.

COMPLAINT filed by All Plaintiffs against All Defendants. Plaintiff requests summons issued. Receipt No: AMIEDC-10102523 - Fee: $ 405. County of 1st Plaintiff: Washtenaw - County Where Action Arose: Washtenaw - County of 1st Defendant: Washtenaw. [Previously dismissed case: No] [Possible companion case(s): None] (Attachments: # 1 Index of Exhibits, # 2 Exhibit A - Declarations of Plaintiffs, # 3 Exhibit B - Trespass Policy, # 4 Exhibit C - Zou Trespass Form, # 5 Exhibit D - DeRidder Email, # 6 Exhibit E - Zou Objection Denial Letter, # 7 Exhibit F - Zou Appeal Decision Letter, # 8 Exhibit G - Kozler Trespass Form, # 9 Exhibit H - Elliott Trespass Form, # 10 Exhibit I - Grant Trespass Form, # 11 Exhibit J - Grant Objection Denial Letter, # 12 Exhibit K - Grant Appeal Decision Letter, # 13 Exhibit L - Vieira Trespass Form, # 14 Exhibit M - Viera Objection Denial Letter) (Wadood, Ramis) (Entered: 02/03/2025)

1 Index of Exhibits

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2 Exhibit A - Declarations of Plaintiffs

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3 Exhibit B - Trespass Policy

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4 Exhibit C - Zou Trespass Form

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5 Exhibit D - DeRidder Email

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6 Exhibit E - Zou Objection Denial Letter

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7 Exhibit F - Zou Appeal Decision Letter

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8 Exhibit G - Kozler Trespass Form

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9 Exhibit H - Elliott Trespass Form

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10 Exhibit I - Grant Trespass Form

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11 Exhibit J - Grant Objection Denial Letter

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12 Exhibit K - Grant Appeal Decision Letter

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13 Exhibit L - Vieira Trespass Form

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14 Exhibit M - Viera Objection Denial Letter

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MOTION for Preliminary Injunction by All Plaintiffs. (Attachments: # 1 Exhibit 1 - Declaration of Stacie Greskowiak McNulty) (Wadood, Ramis) (Entered: 02/03/2025)

1 Exhibit 1 - Declaration of Stacie Greskowiak McNulty

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NOTICE of Appearance by Jack W. Schulz on behalf of All Plaintiffs. (Schulz, Jack) (Entered: 02/03/2025)

NOTICE of Appearance by Daniel S. Korobkin on behalf of All Plaintiffs. (Korobkin, Daniel) (Entered: 02/03/2025)

NOTICE of Appearance by Bonsitu A. Kitaba on behalf of All Plaintiffs. (Kitaba, Bonsitu) (Entered: 02/03/2025)

NOTICE of Appearance by Philip Edwin Mayor on behalf of All Plaintiffs. (Mayor, Philip) (Entered: 02/03/2025)

NOTICE of Appearance by Amanda M. Ghannam on behalf of All Plaintiffs. (Ghannam, Amanda) (Entered: 02/03/2025)

NOTICE of Appearance by John C. Philo on behalf of All Plaintiffs. (Philo, John) (Entered: 02/04/2025)

Notice to Parties of Consent of a Civil Action before a Magistrate Judge Option

Correction

NOTICE of Appearance by Liz Jacob on behalf of All Plaintiffs. (Jacob, Liz) (Entered: 02/04/2025)

A United States Magistrate Judge of this Court is available to conduct all proceedings in this civil action in accordance with 28 U.S.C. 636c and FRCP 73. The Notice, Consent, and Reference of a Civil Action to a Magistrate Judge form is available for download at http://www.mied.uscourts.gov (LGra)

SUMMONS Issued for * All Defendants * (LGra) (Entered: 02/04/2025)

A United States Magistrate Judge of this Court is available to conduct all proceedings in this civil action in accordance with 28 U.S.C. 636c and FRCP 73. The Notice, Consent, and Reference of a Civil Action to a Magistrate Judge form is available for download at http://www.mied.uscourts.gov (THum)

NOTICE of Correction re Notice to Parties of Consent of a Civil Action before a Magistrate Judge Option,. (THum)[Clerk Error, Notice to Parties of Consent of a Civil Action before a Magistrate Judge Option, was previously entered] Modified on 2/4/2025 (THum).

CERTIFICATE of Service/Summons Returned Executed. All Defendants. (Wadood, Ramis) [No Green Card Returned Executed] Modified on 2/6/2025 (THum). (Entered: 02/06/2025)

ORDER OF RECUSAL AND REASSIGNING CASE from Magistrate Judge Anthony P. Patti to Magistrate Judge Elizabeth A. Stafford. (NAhm) (Entered: 02/07/2025)

ORDER REGARDING PROTOCOLS ON FILINGS AND COMMUNICATION WITH THE COURT - Signed by District Judge Mark A. Goldsmith. (CCie) (Entered: 02/11/2025)

NOTICE of Appearance by Delaney Ann Barker on behalf of All Plaintiffs. (Barker, Delaney) (Entered: 02/12/2025)

NOTICE of Appearance by Ishan Bhabha on behalf of Santa J. Ono, Geoffrey Chatas, Eddie L. Washington, Crystal James. (Bhabha, Ishan) (Entered: 02/19/2025)

NOTICE of Appearance by Lauren J. Hartz on behalf of Santa J. Ono, Geoffrey Chatas, Eddie L. Washington, Crystal James. (Hartz, Lauren) (Entered: 02/19/2025)

NOTICE of Appearance by Brian M. Schwartz on behalf of All Defendants. (Schwartz, Brian) (Entered: 02/21/2025)

Text-Only Order

TEXT-ONLY ORDER. The Court orders that:(i) Defendants' time to respond to Plaintiffs' motion for preliminary injunction is extended to March 12, 2025; (ii) Defendants' time to respond to the complaint is suspended until further order of the court; (iii) a status conference will be held by zoom on February 27, 2025 at noon, at which the court will discuss staying discovery, setting a date for Defendants to respond to the complaint, and such other issues as counsel may wish to raise. Signed by District Judge Mark A. Goldsmith. (DPer)

NOTICE TO APPEAR REMOTELY: Status Conference set for 2/27/2025 at 12:00 PM before District Judge Mark A. Goldsmith. (DPer) (Entered: 02/24/2025)

NOTICE of Appearance by Erika L. Giroux on behalf of All Defendants. (Giroux, Erika) (Entered: 02/25/2025)

Minute Entry for remote proceedings before District Judge Mark A. Goldsmith: Telephonic Status Conference held on 2/27/2025 (Court Reporter: None Present, Not on the Record) (AChu)

STIPULATED ORDER REGARDING PAGE LIMITS FOR RESPONSE AND REPLY BRIEFS - Signed by District Judge Mark A. Goldsmith. (CCie) (Entered: 03/05/2025)

RESPONSE to 2 MOTION for Preliminary Injunction filed by Geoffrey Chatas, Crystal James, Santa J. Ono, Eddie L. Washington. (Attachments: # 1 Index of Exhibits, # 2 Exhibit A - Declaration of Eddie Washington and Exhibits 1-4, # 3 Exhibit B - Declaration of Crystal James and Exhibits 5-9, [STRICKEN] # 4 Exhibit C - Declaration of Paul DeRidder and Exhibits 10-30, # 5 Exhibit D - Declaration of Aron Feltes and Exhibit 31) (Hartz, Lauren) Modified on 4/16/2025 (CCie). (Entered: 03/12/2025)

1 Index of Exhibits

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2 Exhibit A - Declaration of Eddie Washington and Exhibits 1-4

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3 Exhibit B - Declaration of Crystal James and Exhibits 5-9

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5 Exhibit D - Declaration of Aron Feltes and Exhibit 31

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REPLY to Response re 2 MOTION for Preliminary Injunction filed by All Plaintiffs. (Attachments: # 1 Index of Exhibits, # 2 Exhibit A -- Declaration of Jonathan Zou, # 3 Exhibit B -- Declaration of Gabriel Vieira, # 4 Exhibit B-1 -- March 17, 2025 Order of Nolle Prosequi, # 5 Exhibit C -- Declaration of Christian Grant, # 6 Exhibit D -- Declaration of Alice Elliott, # 7 Exhibit E -- Defendants' Stipulation Regarding Trespass Ban Modification) (Wadood, Ramis) (Entered: 03/26/2025)

1 Index of Exhibits

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2 Exhibit A -- Declaration of Jonathan Zou

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3 Exhibit B -- Declaration of Gabriel Vieira

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4 Exhibit B-1 -- March 17, 2025 Order of Nolle Prosequi

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5 Exhibit C -- Declaration of Christian Grant

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6 Exhibit D -- Declaration of Alice Elliott

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7 Exhibit E -- Defendants' Stipulation Regarding Trespass Ban Modification

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STIPULATED ORDER STRIKING DKT. 21-4 AND GRANTING LEAVE TO FILE CORRECTED DOCUMENT - Signed by District Judge Mark A. Goldsmith. (CCie) (Entered: 04/16/2025)

EXHIBIT C (Dkt. 21-4) (Corrected) re 21 Response to Motion,, by Geoffrey Chatas, Crystal James, Santa J. Ono, Eddie L. Washington (Hartz, Lauren) (Entered: 04/16/2025)

NOTICE OF IN PERSON HEARING on 2 MOTION for Preliminary Injunction. Motion Hearing set for 5/15/2025 at 11:00 AM before District Judge Mark A. Goldsmith. (HRya) (Entered: 04/29/2025)

MOTION for Withdrawal of Attorney Daniel S. Korobkin by All Plaintiffs. (Korobkin, Daniel) (Entered: 04/30/2025)

MOTION for Withdrawal of Attorney Delaney A. Barker by All Plaintiffs. (Barker, Delaney) (Entered: 04/30/2025)

ORDER granting 26 Motion to Withdraw as Attorney.. Signed by District Judge Mark A. Goldsmith. (KCas) (Entered: 05/01/2025)

ORDER granting 27 Motion to Withdraw as Attorney. Signed by District Judge Mark A. Goldsmith. (KCas) (Entered: 05/01/2025)

CERTIFICATE of Service/Summons Returned Executed. All Defendants. (Mayor, Philip) Modified on 5/2/2025 (JBro). [Service/Returned Executed as to Defendants Santa J. Ono and Geoffrey S. Chatas, service date 2/7/25. As to Crystal James service executed on[2/10/25]. No service date listed on green card for Eddie L. Washington. Additional service attached- University of MI-General Counsel [2/7/25] ] (Entered: 05/01/2025)

Minute Entry for in-person proceedings before District Judge Mark A. Goldsmith: Motion Hearing held on 5/15/2025 re 2 MOTION for Preliminary Injunction filed by Gabriel Vieira, Oliver Kozler, Jonathan Zou, Christian Grant, Alice Elliott. Disposition: Motion taken under advisement. (Court Reporter: David Yarbrough) (JHea)

ORDER Directing Parties to Order Transcript from Hearing Held on May 15, 2025. Signed by District Judge Mark A. Goldsmith. (JHea) (Entered: 05/19/2025)

TRANSCRIPT of Hearing on Plaintiffs' Motion for Preliminary Injunction held on 5/15/2025. (Court Reporter/Transcriber: David B. Yarbrough) (Number of Pages: 70) The parties have 21 days to file with the court and Court Reporter/Transcriber a Redaction Request of this transcript. If no request is filed, the transcript may be made remotely electronically available to the public without redaction after 90 days. Redaction Request due 6/11/2025. Redacted Transcript Deadline set for 6/23/2025. Release of Transcript Restriction set for 8/19/2025. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date, the transcript is publicly available. (Yarbrough, David) (Entered: 05/21/2025)

NOTICE by All Plaintiffs Plaintiffs' Notice of Changed Facts (Attachments: # 1 Exhibit A - Order of Nolle Prosequi) (Wadood, Ramis) (Entered: 05/22/2025)

NOTICE by All Defendants Notice of Changed Facts (Attachments: # 1 Exhibit A, # 2 Exhibit B) (Hartz, Lauren) (Entered: 05/30/2025)

NOTICE by All Defendants Notice of Errata to Transcript of May 15, 2025 Preliminary Injunction Hearing (Hartz, Lauren) (Entered: 05/30/2025)

NOTICE by All Plaintiffs re 32 Transcript,,, Notice of Errata (Wadood, Ramis) (Entered: 06/12/2025)

NOTICE TO APPEAR REMOTELY VIA ZOOM: Status Conference set for 7/17/2025 01:30 PM before District Judge Mark A. Goldsmith. (JHea) (Entered: 07/15/2025)

AMENDED NOTICE TO APPEAR REMOTELY VIA ZOOM: Status Conference set for 7/17/2025 01:30 PM before District Judge Mark A. Goldsmith. |Remote Access Phone Number: +1 (646) 828-7666 and Meeting ID: 160 201 0383| (JHea) (Entered: 07/16/2025)

Minute Entry for remote proceedings before District Judge Mark A. Goldsmith: Status Conference held on 7/17/2025 (Court Reporter: David Yarbrough) (EBut)

Joint STATEMENT of Proposed Case Management Schedule by Geoffrey Chatas, Crystal James, Santa J. Ono, Eddie L. Washington (Hartz, Lauren) (Entered: 07/31/2025)

TEXT-ONLY ORDER: The parties must file a supplemental joint submission regarding the proposed Case Management Schedule addressing the following: (i) what issues do the parties expect to present at trial that will be the subject of expert opinion, (ii) how many fields of expertise will be involved, (iii) what is the approximate number of expert witnesses who are expected to be called at trial by both sides. The submission must be filed by 8/10/2025. Submission due by 8/10/2025. SO ORDERED. Issued by District Judge Mark A. Goldsmith. (JHea)

Text-Only Order AND ~Util - Set Deadlines/Hearings

Joint Supplemental STATEMENT of Expert Discovery by All Plaintiffs (Wadood, Ramis) (Entered: 08/08/2025)

CASE MANAGEMENT AND SCHEDULING ORDER: Discovery due by 5/1/2026, Dispositive Motion Cut-off set for 5/22/2026. Signed by District Judge Mark A. Goldsmith. (Refer to image for additional dates) (JHea) (Entered: 08/13/2025)

NOTICE of Voluntary Dismissal by Gabriel Vieira as to Gabriel Vieira (Wadood, Ramis) (Entered: 08/20/2025)

ANSWER to Complaint with Affirmative Defenses by Geoffrey Chatas, Crystal James, Santa J. Ono, Eddie L. Washington. (Hartz, Lauren) (Entered: 08/22/2025)

NOTICE of Appearance by Syeda F. Davidson on behalf of Alice Elliott, Christian Grant, Oliver Kozler, Jonathan Zou. (Davidson, Syeda) (Entered: 08/27/2025)

AMENDED COMPLAINT filed by Alice Elliott, Oliver Kozler, Christian Grant, Jonathan Zou, Emily Wall, Rowan Tucker-Meyer against Geoffrey Chatas, Crystal James, Domenico Grasso, Richard Arnold. NEW PARTIES ADDED. (Attachments: # 1 Index of Exhibits, # 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, # 11 Exhibit J, # 12 Exhibit K, # 13 Exhibit L, # 14 Exhibit M) (Wadood, Ramis) (Entered: 08/27/2025)

STIPULATED ORDER REGARDING DEADLINE FOR RESPONSIVE PLEADING. Responsive Pleading due by 9/24/2025. Signed by District Judge Mark A. Goldsmith. (JHea) (Entered: 09/08/2025)

TEXT-ONLY ORDER: Based on the notice of voluntary dismissal filed by Plaintiff Gabriel Vieira (Dkt. 42), his claims are dismissed without prejudice. SO ORDERED. Issued by District Judge Mark A. Goldsmith. (JHea)

Text-Only Order

ANSWER to Amended Complaint with Affirmative Defenses by Richard Arnold, Geoffrey Chatas, Domenico Grasso, Crystal James. (Hartz, Lauren) (Entered: 09/24/2025)

STIPULATED CONFIDENTIALITY AND PROTECTIVE ORDER Signed by Magistrate Judge Elizabeth A. Stafford. (DAll) (Entered: 09/25/2025)

ORDER DENYING WITHOUT PREJUDICE Plaintiffs' 2 Motion for a Preliminary Injunction. Signed by District Judge Mark A. Goldsmith. (JHea) (Entered: 09/29/2025)

ORDER DENYING WITHOUT PREJUDICE Plaintiffs' 2 Motion for a Preliminary Injunction. Signed by District Judge Mark A. Goldsmith. (JHea) (Entered: 09/29/2025)

NOTICE of Appearance by Allison N. Douglis on behalf of Richard Arnold, Geoffrey Chatas, Domenico Grasso, Crystal James. (Douglis, Allison) (Entered: 11/11/2025)

NOTICE of Change of Address/Contact Information by Amanda M. Ghannam on behalf of All Plaintiffs. (Ghannam, Amanda) (Entered: 12/09/2025)

NOTICE of Appearance by Marc Sebastian Allen on behalf of All Plaintiffs. (Allen, Marc) (Entered: 12/11/2025)

Plaintiffs' Expert WITNESS LIST by All Plaintiffs (Wadood, Ramis) (Entered: 12/31/2025)

MOTION to Compel Discovery and Extend Remaining Deadlines by All Plaintiffs. (Attachments: # 1 Index of Exhibits, # 2 Exhibit A - Plaintiffs' First Set of Interrogatories, # 3 Exhibit B - Plaintiffs' First Set of RFPs, # 4 Exhibit C - Defendants' Responses to Plaintiffs' First Set of Interrogatories, # 5 Exhibit D - Defendants' Responses Plaintiffs' First Set of Requests for Production, # 6 Exhibit E - 11.14.25 Letter to Defendants, # 7 Exhibit F - 11.25.25 Letter from Defendants, # 8 Exhibit G - 12.18.25 Letter to Defendants, # 9 Exhibit H - 1.6.26 Letter from Defendants, # 10 Exhibit I - 1.9.26 Letter to Defendants, # 11 Exhibit J - 1.14.26 Letter from Defendants, # 12 Exhibit K - 1.16.26 Letter to Defendants, # 13 Exhibit L - 12.10.25 email to Defendants) (Allen, Marc) (Entered: 01/16/2026)

RESPONSE to 54 MOTION to Compel Discovery and Extend Remaining Deadlines filed by Richard Arnold, Geoffrey Chatas, Domenico Grasso, Crystal James. (Attachments: # 1 Declaration in Support of Opposition to Motion) (Hartz, Lauren) (Entered: 01/30/2026)

Exhibit List by All Plaintiffs. (Wadood, Ramis) (Entered: 02/02/2026)

Lay WITNESS LIST by All Plaintiffs (Wadood, Ramis) (Entered: 02/02/2026)

Exhibit List by Richard Arnold, Geoffrey Chatas, Domenico Grasso, Crystal James. (Hartz, Lauren) (Entered: 02/02/2026)

LAY WITNESS LIST by Richard Arnold, Geoffrey Chatas, Domenico Grasso, Crystal James (Hartz, Lauren) (Entered: 02/02/2026)

STIPULATED ORDER EXTENDING DEADLINE FOR DEFENDANTS' EXPERT DISCLOSURES. Signed by District Judge Mark A. Goldsmith. (JHea) (Entered: 02/04/2026)

REPLY to Response re 54 MOTION to Compel Discovery and Extend Remaining Deadlines filed by All Plaintiffs. (Allen, Marc) (Entered: 02/06/2026)

Defendants' Expert WITNESS LIST by All Defendants (Hartz, Lauren) (Entered: 02/23/2026)

NOTICE TO APPEAR REMOTELY VIA ZOOM: Status Conference set for 3/10/2026 04:30 PM before District Judge Mark A. Goldsmith. (JHea) (Entered: 03/04/2026)

MOTION for Protective Order by All Plaintiffs. (Attachments: # 1 Exhibit A) (Wadood, Ramis) (Entered: 03/06/2026)

RESPONSE to 64 MOTION for Protective Order filed by Richard Arnold, Geoffrey Chatas, Domenico Grasso, Crystal James. (Attachments: # 1 Index of Exhibits, # 2 Exhibit A - Declaration of Lauren J. Hartz In Support of Defendants' Opposition to Plaintiffs' Motion for a Protective Order, # 3 Exhibit 1 - Alice Elliott March 15, 2019 Fleming Administration Building Trespass Warning Form, # 4 Exhibit 2 - Defendants' First Set of Interrogatories and Document Requests, # 5 Exhibit 3 - Alice Elliott's Responses to Defendants' First Set of Interrogatories and Document Requests, # 6 Exhibit 4 - Alice Elliott's Supplemented Responses to Defendants' First Set of Interrogatories and Document Requests, # 7 Exhibit 5 - Alice Elliott's Second Supplemented Responses to Defendants' First Set of Interrogatories and Document Requests, # 8 Exhibit 6 - Alice Elliott's Third Supplemented Responses to Defendants' First Set of Interrogatories and Document Requests, # 9 Exhibit 7 - Alice Elliott's Fourth Supplemented Responses to Defendants' First Set of Interrogatories and Document Requests, # 10 Exhibit 8 - Alice Elliott's Fifth Supplemented Responses to Defendants' First Set of Interrogatories and Document Requests, # 11 Exhibit 9 - Docket Sheet for Mountain Valley Pipeline, LLC v. Moore et al., Case No. CL23-1242, # 12 Exhibit 10 - Amended Complaint Dated September 5, 2023, in Mountain Valley Pipeline, LLC v. Moore et al., Case No. CL23-1242, # 13 Exhibit 11 - Settlement Order Dated November 6, 2025, in Mountain Valley Pipeline, LLC v. Moore et al., Case No. CL23-1242, # 14 Exhibit 12 - March 5, 2026 Email from Plaintiffs' Counsel titled Zou v. Grasso | Deposition of Alice Elliott, # 15 Exhibit 13 - March 6, 2026 Email from Plaintiffs' Counsel titled Zou | Supplemental Response Related to Motion for Protective Order, # 16 Exhibit 14 - April 20, 2021 News Article, # 17 Exhibit 15 - April 21, 2021 News Article, # 18 Exhibit 16 - April 20, 2021 Instagram Post, # 19 Exhibit 17 - Giles General District Court Case Information for Case No. GC21001738, # 20 Exhibit 18 - Giles Circuit Court Case Information for Case No. CR21000271, # 21 Exhibit 19 - Giles General District Court Case Information for Case No. GC21001739, # 22 Exhibit 20 - Giles Circuit Court Case Information for Case No. CR21000272, # 23 Exhibit 21 - Giles General District Court Case Information for Case No. GC21001740, # 24 Exhibit 22 - Giles General District Court Case Information for Case No. GC21001741) (Hartz, Lauren) (Entered: 03/09/2026)

Minute Entry for remote proceedings before District Judge Mark A. Goldsmith: Status Conference held on 3/10/2026 (Court Reporter: None Present, Not on the Record) (JHea)

NOTICE by All Plaintiffs of withdrawal of 64 MOTION for Protective Order . (Allen, Marc) (Entered: 03/12/2026)

MOTION to Quash Defendants' Subpoenas for Documents to Third Parties by Denise Heberle, Josiah Walker, Eaman Ali, Stacie McNulty. (Attachments: # 1 Exhibit Ex. A, # 2 Exhibit Ex. B, # 3 Exhibit Ex. C, # 4 Exhibit Ex. D) (Christensen, Benjamin) (Entered: 03/30/2026)

1 Exhibit Ex. A

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2 Exhibit Ex. B

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3 Exhibit Ex. C

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4 Exhibit Ex. D

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NOTICE of Appearance by Andre Damian Williams on behalf of Richard Arnold, Geoffrey Chatas, Domenico Grasso, Crystal James. (Williams, Andre) (Entered: 04/03/2026)

NOTICE of Appearance by William S.C. Goldstein on behalf of Richard Arnold, Geoffrey Chatas, Domenico Grasso, Crystal James. (Goldstein, William) (Entered: 04/03/2026)

NOTICE re 67 MOTION to Quash Defendants' Subpoenas for Documents to Third Parties Third Parties' Notice of Recent Development (Attachments: # 1 Exhibit Ex. A, # 2 Exhibit Ex. B) (Christensen, Benjamin) (Entered: 04/15/2026)

STIPULATED ORDER Extending Deadlines Concerning Nonparty Movants' Motion to Quash or, Alternatively, for a Protective Order. Set Motion Deadlines as to 67 MOTION to Quash Defendants' Subpoenas for Documents to Third Parties: (Response due by 4/20/2026, Reply due by 5/1/2026) Signed by District Judge Mark A. Goldsmith. (RThi) (Entered: 04/17/2026)

JOINT STIPULATION Extending Case Deadlines. (Discovery due by 5/15/2026, Dispositive Motion Cut-off set for 6/5/2026) Signed by District Judge Mark A. Goldsmith. (RThi) (Entered: 04/17/2026)

RESPONSE to 67 MOTION to Quash Defendants' Subpoenas for Documents to Third Parties Denise Heberle, Stacie McNulty, Josiah Walker, Eaman Ali filed by Richard Arnold, Geoffrey Chatas, Domenico Grasso, Crystal James. (Attachments: # 1 Index of Exhibits, # 2 Declaration of Lauren J. Hartz in Support, # 3 Exhibit 1 - Plaintiffs' Rule 26(a)(1)(A) Initial Disclosures, # 4 Exhibit 2 - Plaintiffs' Rule 26(a)(1)(A) First Supplemental Initial Disclosures, # 5 Exhibit 3 - February 9, 2026 Email, # 6 Exhibit 4 - Plaintiffs' Rule 26(a)(1)(A) Second Supplemental Initial Disclosures, # 7 Exhibit 5 - Defendants' First Set of Interrogatories and Document Requests to Jonathan Zou, # 8 Exhibit 6 - November 25, 2025 Letter, # 9 Exhibit 7 - January 9, 2026 Letter, # 10 Exhibit 8 - February 23, 2026 Letter, # 11 Exhibit 9 - Denise Heberle's Responses and Objections to Defendants' Requests for Production, # 12 Exhibit 10 - March 20, 2026 Letter, # 13 Exhibit 11 - Jonathan Zou Deposition Transcript Excerpts, # 14 Exhibit 12 - March 30, 2026 Letter, # 15 Exhibit 13 - Oliver Kozler Deposition Transcript Excerpts, # 16 Exhibit 14 - Christian Grant Deposition Transcript Excerpts, # 17 Exhibit 15 - Emily Wall Deposition Transcript Excerpts, # 18 Exhibit 16 - April 9, 2026 Letter, # 19 Exhibit 17 - March 27, 2026 Email, # 20 Exhibit 18 - Pl.000006-000007, # 21 Exhibit 19 - Pl.000556) (Hartz, Lauren) (Entered: 04/20/2026)

1 Index of Exhibits

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2 Declaration of Lauren J. Hartz in Support

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3 Exhibit 1 - Plaintiffs' Rule 26(a)(1)(A) Initial Disclosures

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4 Exhibit 2 - Plaintiffs' Rule 26(a)(1)(A) First Supplemental Initial Disclos

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5 Exhibit 3 - February 9, 2026 Email

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6 Exhibit 4 - Plaintiffs' Rule 26(a)(1)(A) Second Supplemental Initial Disclo

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7 Exhibit 5 - Defendants' First Set of Interrogatories and Document Requests

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8 Exhibit 6 - November 25, 2025 Letter

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9 Exhibit 7 - January 9, 2026 Letter

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10 Exhibit 8 - February 23, 2026 Letter

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11 Exhibit 9 - Denise Heberle's Responses and Objections to Defendants' R

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12 Exhibit 10 - March 20, 2026 Letter

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13 Exhibit 11 - Jonathan Zou Deposition Transcript Excerpts

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14 Exhibit 12 - March 30, 2026 Letter

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15 Exhibit 13 - Oliver Kozler Deposition Transcript Excerpts

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16 Exhibit 14 - Christian Grant Deposition Transcript Excerpts

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17 Exhibit 15 - Emily Wall Deposition Transcript Excerpts

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18 Exhibit 16 - April 9, 2026 Letter

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19 Exhibit 17 - March 27, 2026 Email

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20 Exhibit 18 - Pl.000006-000007

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21 Exhibit 19 - Pl.000556

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SEALED RESPONSE re 67 Motion to Quash, Provisionally Sealed Pursuant to ECF No. 48, by Richard Arnold, Geoffrey Chatas, Domenico Grasso, Crystal James. (Attachments: # 1 Exhibit 10 - March 20, 2026 Letter, # 2 Exhibit 11 - Jonathan Zou Deposition Transcript Excerpts, # 3 Exhibit 12 - March 30, 2026 Letter, # 4 Exhibit 13 - Oliver Kozler Deposition Transcript Excerpts, # 5 Exhibit 14 - Christian Grant Deposition Transcript Excerpts, # 6 Exhibit 15 - Emily Wall Deposition Transcript Excerpts, # 7 Exhibit 16 - April 9, 2026 Letter) (Hartz, Lauren) (Entered: 04/20/2026)

MOTION to Quash Defendants' Deposition Subpoenas to Third Parties by Denise Heberle, Stacie McNulty. (Attachments: # 1 Exhibit Ex. A, # 2 Exhibit Ex. B) (Christensen, Benjamin) (Entered: 04/27/2026)

Second MOTION to Compel Discovery by All Plaintiffs. (Attachments: # 1 Index of Exhibits, # 2 Exhibit A - Plaintiffs' Second Set of RFPs, # 3 Exhibit B - Defendants' Responses to Plaintiffs' Second Set of RFPs, # 4 Exhibit C - April 7 Letter to Defendants, # 5 Exhibit D - April 15 Letter to Plaintiffs, # 6 Exhibit E - April 9 Letter to Defendants (redacted), # 7 Exhibit F - April 24 Letter to Plaintiffs, # 8 Exhibit G - April 23 Letter to Defendants (redacted), # 9 Exhibit H - April 29 Letter to Plaintiffs (redacted), # 10 Exhibit I - Paul Deridder Dep Tr (placeholder), # 11 Exhibit J - Ryan Cavanaugh Dep Tr (placeholder), # 12 Exhibit K - Brent Carriveau Dep Tr (placeholder), # 13 Exhibit L - Anthony Humphrey Dep Tr (placeholder), # 14 Exhibit M - Matthew Napieralski Dep Tr (placeholder)) (Allen, Marc) (Entered: 04/30/2026)

SEALED MOTION to Compel Discovery (Second) by All Plaintiffs. (Attachments: # 1 Index of Exhibits, # 2 Exhibit E - April 9 Letter to Defendants, # 3 Exhibit G - April 23 Letter to Defendants, # 4 Exhibit H - April 29 Letter to Plaintiffs, # 5 Exhibit I - Paul DeRidder Dep Tr, # 6 Exhibit J - Ryan Cavanaugh Dep Tr, # 7 Exhibit K - Brent Carriveau Dep Tr, # 8 Exhibit L - Anthony Humphrey Dep Tr, # 9 Exhibit M - Matthew Napieralski Dep Tr) (Allen, Marc) (Entered: 04/30/2026)

Exhibit List by All Defendants. (Hartz, Lauren) (Entered: 05/01/2026)

Supplemental WITNESS LIST by All Defendants (Hartz, Lauren) (Entered: 05/01/2026)

MOTION to Compel Discovery by All Defendants. (Attachments: # 1 Index of Exhibits, # 2 Declaration of L. Hartz, # 3 Exhibit 1 Defendants' March 20, 2026 Letter, # 4 Exhibit 2 Defendants' March 30, 2026 Letter (Redacted), # 5 Exhibit 3 Defendants' April 1, 2026 Letter, # 6 Exhibit 4 Plaintiffs' April 9, 2026 Letter (Redacted), # 7 Exhibit 5 Defendants' First Set of Interrogatories and Document Requests, # 8 Exhibit 6 Defendants' November 25, 2025 Letter, # 9 Exhibit 7 Plaintiffs' December 18, 2025 Letter, # 10 Exhibit 8 Defendants' January 6, 2026 Letter, # 11 Exhibit 9 Excerpts of Alice Elliott's First Supplemented Discovery Responses, # 12 Exhibit 10 Excerpts of Emily Wall's First Supplemented Discovery Responses, # 13 Exhibit 11 Excerpts of Rowan Tucker-Meyer's First Supplemented Discovery Responses, # 14 Exhibit 12 Plaintiffs' January 9, 2026 Letter, # 15 Exhibit 13 Excerpts of Jonathan Zou's Responses to Discovery Requests, # 16 Exhibit 14 Excerpts of Oliver Kozler's Deposition Transcript, # 17 Exhibit 15 Excerpts of Alice Elliott's Deposition Transcript, # 18 Exhibit 16 Excerpts of Emily Wall's Deposition Transcript, # 19 Exhibit 17 Excerpts of Christian Grant's Deposition Transcript (Sealed), # 20 Exhibit 18 Defendants' March 23, 2026 Email, # 21 Exhibit 19 Excerpts of Jonathan Zou's Deposition Transcript (Redacted), # 22 Exhibit 20 Excerpts of Rowan Tucker-Meyer's Deposition Transcript (Sealed), # 23 Exhibit 21 PI.000324, PI.000325, Pl.000328, Pl.000356, and Pl.000367, # 24 Exhibit 22 Pl.0001366, Pl.0001373, and Pl.0001380, # 25 Exhibit 23 Pl.000426, # 26 Exhibit 24 Pl.001359, PI.001362) (Hartz, Lauren) (Entered: 05/01/2026)

SEALED MOTION to Compel Discovery by All Defendants. (Attachments: # 1 Exhibit 2 Defendants' March 30, 2026 Letter (Unredacted), # 2 Exhibit 4 Plaintiffs' April 9, 2026 Letter (Unredacted), # 3 Exhibit 17 Excerpts of Christian Grant's Deposition Transcript (Unsealed), # 4 Exhibit 19 Excerpts of Jonathan Zou's Deposition Transcript (Unredacted), # 5 Exhibit 20 Excerpts of Rowan Tucker-Meyer's Deposition Transcript (Unsealed)) (Hartz, Lauren) (Entered: 05/01/2026)

NOTICE re 73 Response to Motion,,,,, of Publicly Filed Exhibits (Attachments: # 1 Exhibit 10 - March 20, 2026 Letter, # 2 Exhibit 11 - Jonathan Zou Deposition Transcript Excerpts, # 3 Exhibit 12 - March 30, 2026 Letter, # 4 Exhibit 13 - Oliver Kozler Deposition Transcript Excerpts, # 5 Exhibit 14 - Christian Grant Deposition Transcript Excerpts, # 6 Exhibit 15 - Emily Wall Deposition Transcript Excerpts, # 7 Exhibit 16 - April 9, 2026 Letter) (Hartz, Lauren) (Entered: 05/04/2026)

1 Exhibit 10 - March 20, 2026 Letter

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2 Exhibit 11 - Jonathan Zou Deposition Transcript Excerpts

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3 Exhibit 12 - March 30, 2026 Letter

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4 Exhibit 13 - Oliver Kozler Deposition Transcript Excerpts

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5 Exhibit 14 - Christian Grant Deposition Transcript Excerpts

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6 Exhibit 15 - Emily Wall Deposition Transcript Excerpts

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7 Exhibit 16 - April 9, 2026 Letter

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Reply to Response to Motion

Extension of Time to File Response/Reply