Case: Doe ex rel. Doe v. Haley

Doe v. Haley

NOTICE OF REMOVAL from Court of Common Pleas, Abbeville County, case number 2013-CP-01-104. (Filing fee $400 receipt number 0420-4799962), filed by Merry Eve Poole, Department of Social Services, Ursula Best, Cassandra Daniels, Robin Kubler. (Attachments: # 1 State Court Answer, # 2 State Court Summons and Amended Complaint)(mbro) (Entered: 06/28/2013)

1 State Court Answer

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2 State Court Summons and Amended Complaint

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Local Rule 26.01 Answers to Interrogatories by Ursula Best, Cassandra Daniels, Department of Social Services, Robin Kubler, Merry Eve Poole.(mbro) (Entered: 06/28/2013)

CERTIFICATE OF SERVICE by Ursula Best, Cassandra Daniels, Department of Social Services, Robin Kubler, Merry Eve Poole re 1 Notice of Removal, 3 Local Rule 26.01 Answers to Interrogatories (mbro) (Entered: 06/28/2013)

NOTICE TO COUNSEL - All future pleadings submitted for filing must contain the attorney's graphical signature instead of the s/typed name. This should be accomplished through the use of a graphical signature inserted on a created document and not a signed signature on a printed document that is subsequently scanned. Pursuant to the Judicial Filing Preferences, All legal memoranda MUST be converted rather than scanned. Please refer to these preferences for all additional pleadings.(mbro) (Entered: 06/28/2013)

NOTICE of Appearance by Robert J Butcher on behalf of John Doe (Butcher, Robert) (Main Document 8 replaced on 7/2/2013) (alew, ). Modified on 7/2/2013 to replace with corrected document provided by filing user(alew, ). (Entered: 07/01/2013)

NOTICE of Appearance by Heather Hite Stone on behalf of John Doe (Stone, Heather) (Main Document 9 replaced on 7/2/2013) (alew, ). Modified on 7/2/2013 to replace with corrected document provided by filing user (alew, ). (Entered: 07/01/2013)

NOTICE of Appearance by Kenneth Paul Woodington on behalf of Nikki Haley (Woodington, Kenneth) (Main Document 13 replaced on 7/2/2013) (alew, ). Modified on 7/2/2013 to replace with corrected document provided by filing user (alew, ). (Entered: 07/01/2013)

CERTIFICATE OF SERVICE by Ursula Best, Cassandra Daniels, Robin Kubler, Merry Eve Poole re 1 Notice of Removal, (Logan, James) (Entered: 07/01/2013)

ANSWER to Amended State Court Complaint by Donna D Outen.(Frawley, Patrick) Modified on 7/2/2013 to edit text(alew, ). (Entered: 07/01/2013)

ANSWER to Amended State Court Complaint by Robert Seepersaud.(Frawley, Patrick) Modified on 7/2/2013 to edit text (alew, ). (Entered: 07/01/2013)

Local Rule 26.01 Answers to Interrogatories by Donna D Outen.(Frawley, Patrick) (Entered: 07/01/2013)

Local Rule 26.01 Answers to Interrogatories by Robert Seepersaud.(Frawley, Patrick) (Entered: 07/01/2013)

SUMMONS Returned Executed by John Doe. (Attachments: # 1 State Court Documents Exhibit 1 - Nikki Haley Acceptance of Service, # 2 State Court Documents Exhibit 2 - Boys Home of the South Acceptance of Service, # 3 State Court Documents Exhibit 3 - Donna Outen Acceptance of Service, # 4 State Court Documents Exhibit 4 - Robert Seepersaud Acceptance of Service, # 5 State Court Documents Exhibit 5 - Cassandra Daniels, # 6 State Court Documents Exhibit 6 - Ursula Best Acceptance of Service, # 7 State Court Documents Exhibit 7 - Charlene Robinson Acceptance of Service, # 8 State Court Documents Exhibit 8 - Lillian Koller Acceptance of Service, # 9 State Court Documents Exhibit 9 - Debra Wise Acceptance of Service, # 10 State Court Documents Exhibit 10 - Merry Eve Poole Acceptance of Service, # 11 State Court Documents Exhibit 11 - Patricia Boswell Acceptance of Service, # 12 State Court Documents Exhibit 12 - Isabel Blanco Acceptance of Service, # 13 State Court Documents Exhibit 13 - Kathleen Hayes Acceptance of Service, # 14 State Court Documents Exhibit 14 - Robin Kubler Acceptance of Service)(Butcher, Robert) Modified on 7/2/2013 to edit text(alew, ). Modified on 7/2/2013 to correct filing date(alew, ). (Entered: 07/02/2013)

1 State Court Documents Exhibit 1 - Nikki Haley Acceptance of Service

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2 State Court Documents Exhibit 2 - Boys Home of the South Acceptance of Service

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3 State Court Documents Exhibit 3 - Donna Outen Acceptance of Service

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4 State Court Documents Exhibit 4 - Robert Seepersaud Acceptance of Service

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5 State Court Documents Exhibit 5 - Cassandra Daniels

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6 State Court Documents Exhibit 6 - Ursula Best Acceptance of Service

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7 State Court Documents Exhibit 7 - Charlene Robinson Acceptance of Service

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8 State Court Documents Exhibit 8 - Lillian Koller Acceptance of Service

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9 State Court Documents Exhibit 9 - Debra Wise Acceptance of Service

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10 State Court Documents Exhibit 10 - Merry Eve Poole Acceptance of Service

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11 State Court Documents Exhibit 11 - Patricia Boswell Acceptance of Service

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12 State Court Documents Exhibit 12 - Isabel Blanco Acceptance of Service

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13 State Court Documents Exhibit 13 - Kathleen Hayes Acceptance of Service

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14 State Court Documents Exhibit 14 - Robin Kubler Acceptance of Service

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SUMMONS Returned Executed by John Doe. Department of Social Services served. (Attachments: # 1 Affidavit of Service - SCDSS)(Butcher, Robert) Modified on 7/2/2013 to edit text, to remove duplicate text (alew, ). Modified on 7/2/2013 to correct filing date (alew, ). (Entered: 07/02/2013)

1 Affidavit Affidavit of Service - SCDSS

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DELETION OF DOCKET ENTRY NUMBERS 7-10,11,12,14-17,19,20-26 Reason: attorney refiled corrected document. Corrected Filing Document Number 31, 32 Modified filing date to that of original filing: 7/1/13 (alew, ) (Entered: 07/02/2013)

ANSWER to Amended State Court Complaint by Department of Social Services.(Logan, James) Modified on 7/3/2013 to edit text (alew, ). (Entered: 07/02/2013)

ANSWER to Amended State Court Complaint by Ursula Best, Cassandra Daniels, Robin Kubler, Merry Eve Poole.(Logan, James) Modified on 7/3/2013 to edit text(alew, ). (Entered: 07/02/2013)

MOTION to Strike by Department of Social Services. Response to Motion due by 7/19/2013. No proposed order.(Logan, James) (Entered: 07/02/2013)

MOTION to Strike by Ursula Best, Cassandra Daniels, Robin Kubler, Merry Eve Poole. Response to Motion due by 7/19/2013. No proposed order.(Logan, James) (Entered: 07/02/2013)

MOTION for More Definite Statement by Department of Social Services. Response to Motion due by 7/19/2013. No proposed order.(Logan, James) (Entered: 07/02/2013)

MOTION for More Definite Statement by Ursula Best, Cassandra Daniels, Robin Kubler, Merry Eve Poole. Response to Motion due by 7/19/2013. No proposed order.(Logan, James) (Entered: 07/02/2013)

ANSWER to Amended State Court Complaint by Patricia Boswell, Charlene Robinson, Debra Wise.(Matthews, Eugene) Modified on 7/3/2013 to edit text(alew, ). (Entered: 07/03/2013)

Local Rule 26.01 Answers to Interrogatories by Patricia Boswell, Charlene Robinson, Debra Wise.(Matthews, Eugene) (Entered: 07/03/2013)

ANSWER to Complaint by Nikki Haley.(Woodington, Kenneth) (Main Document 43 replaced on 7/8/2013) (alew, ). Modified on 7/8/2013 to replace with corrected document provided by filing user (alew, ). (Entered: 07/03/2013)

Local Rule 26.01 Answers to Interrogatories by Nikki Haley.(Woodington, Kenneth) (Main Document 44 replaced on 7/8/2013) (alew, ). Modified on 7/8/2013 to replace with corrected document provided by filing user(alew, ). (Entered: 07/03/2013)

SUMMONS Returned Executed by John Doe. Cynthia Brock served on 6/28/2013, answer due 7/19/2013; Vernon Hayes served on 6/28/2013, answer due 7/19/2013; Richelle Owens served on 6/28/2013, answer due 7/19/2013. (Attachments: # 1 Exhibit 1 - Cynthia Brock Acceptance of Service, # 2 Exhibit 2 - Richelle Owens Acceptance of Service, # 3 Exhibit 3 - Vernon Hayes Acceptance of Service)(Butcher, Robert) Modified on 7/8/2013 to remove duplicative text(alew, ). (Entered: 07/03/2013)

1 Exhibit 1 - Cynthia Brock Acceptance of Service

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2 Exhibit 2 - Richelle Owens Acceptance of Service

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3 Exhibit 3 - Vernon Hayes Acceptance of Service

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ANSWER to Complaint by Isabel Blanco, Lillian Koller. (Hughes, Joel) Modified on 7/8/2013 to remove document incorrectly filed as an attachment. Filed by the clerk as docket entry 52 (alew, ). (Entered: 07/03/2013)

Local Rule 26.01 Answers to Interrogatories by Isabel Blanco, Lillian Koller. (alew, ) (Entered: 07/08/2013)

ANSWER to Complaint by Boys of the South Inc.(Dowling, Curtis) (Entered: 07/05/2013)

Local Rule 26.01 Answers to Interrogatories by Boys of the South Inc.(Dowling, Curtis) (Entered: 07/05/2013)

DISCLOSURE STATEMENT PURSUANT TO FRCP 7.1 by Boys of the South Inc.(Dowling, Curtis) (Entered: 07/05/2013)

ANSWER to Complaint by Kathleen Hayes.(Wlodarczyk, Damon) (Main Document 50 replaced on 7/9/2013) (alew, ). Modified on 7/9/2013 to replace with corrected document provided by filing user(alew, ). (Entered: 07/05/2013)

Local Rule 26.01 Answers to Interrogatories by Kathleen Hayes.(Wlodarczyk, Damon) (Main Document 51 replaced on 7/9/2013) (alew, ). Modified on 7/9/2013 to replace with corrected document provided by filing user (alew, ). (Entered: 07/05/2013)

NOTICE of Appearance by Matthew Gregory Gerrald on behalf of Boys of the South Inc (Gerrald, Matthew) (Entered: 07/08/2013)

SUMMONS Returned Executed by John Doe. Johnny Jones served 7/7/13, answer due 7/28/13. (Butcher, Robert) Modified on 7/9/2013 to edit text (alew, ). (Entered: 07/08/2013)

DELETION OF DOCKET ENTRY NUMBER 54 Reason: per attorney request (alew, ) (Entered: 07/08/2013)

MOTION to Appear Pro Hac Vice by Ira P. Lustbader ( Filing fee $ 250 receipt number 0420-4815188) by John Doe. Response to Motion due by 7/26/2013. (Attachments: # 1 Exhibit Application for Pro Hac Vice, # 2 Exhibit Certificate of Good Standing)Proposed order is being emailed to chambers with copy to opposing counsel.(Butcher, Robert) Modified on 7/9/2013 to correct spelling (alew, ). (Main Document 57 replaced on 7/9/2013) (alew, ). Modified on 7/9/2013 to replace with corrected document per attorney request (alew, ). (Entered: 07/09/2013)

1 Exhibit Application for Pro Hac Vice

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2 Exhibit Certificate of Good Standing

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MOTION to Appear Pro Hac Vice by Marcia Robinson Lowry ( Filing fee $ 250 receipt number 0420-4815272) by John Doe. Response to Motion due by 7/26/2013. (Attachments: # 1 Exhibit Application for Admission, # 2 Exhibit Certificate of Good Standing)Proposed order is being emailed to chambers with copy to opposing counsel.(Butcher, Robert) Modified on 7/9/2013 to correct spelling (alew, ). (Main Document 58 replaced on 7/9/2013) (alew, ). Modified on 7/9/2013 to replace with corrected document per attorney request (alew, ). (Entered: 07/09/2013)

1 Exhibit Application for Admission

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2 Exhibit Certificate of Good Standing

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Amended Local Rule 26.01 Answers to Interrogatories by Boys of the South Inc.(Dowling, Curtis) (Entered: 07/10/2013)

CONFERENCE AND SCHEDULING ORDER: Rule 26(f) Conference Deadline 7/30/2013, 26(a) Initial Disclosures due by 8/13/2013, Rule 26 Report due by 8/13/2013, Motions to Amend Pleadings due by 8/26/2013, Plaintiffs ID of Expert Witness due by 9/25/2013, Defendants ID of Expert Witnesses Due by 10/25/2013, Records Custodian Affidavit due by 10/25/2013, Discovery due by 12/24/2013, Motions due by 1/3/2014, Rule 26(a)(3) Disclosures due by 3/7/2014, Jury Selection Deadline 4/7/2014, Mediation Due by 3/28/2014. Signed by Honorable G Ross Anderson, Jr on 7/10/13. (alew, ) (Entered: 07/10/2013)

ORDER granting 57 Motion to Appear Pro Hac Vice as to Ira Lustbader for John Doe. Signed by Honorable G Ross Anderson, Jr on 7/11/13.(alew, ) (Entered: 07/11/2013)

ORDER granting 58 Motion to Appear Pro Hac Vice as to Marcia Lowry for John Doe. Signed by Honorable G Ross Anderson, Jr on 7/11/13.(alew, ) (Entered: 07/11/2013)

Local Rule 26.01 Answers to Interrogatories by John Doe.(Butcher, Robert) Modified on 7/12/2013 to remove duplicative text(alew, ). (Entered: 07/12/2013)

ANSWER to Complaint by Cynthia Brock, Vernon Hayes, Nicole Lindsey, Richelle Owens.(Dowling, Curtis) (Entered: 07/18/2013)

Local Rule 26.01 Answers to Interrogatories by Cynthia Brock, Vernon Hayes, Nicole Lindsey, Richelle Owens.(Dowling, Curtis) (Entered: 07/18/2013)

SUMMONS Returned Executed by John Doe. Nicole Lindsey served on 7/17/2013, answer due 8/7/2013. (Attachments: # 1 Exhibit Acceptance of Service)(Butcher, Robert) (Entered: 07/18/2013)

1 Exhibit Acceptance of Service

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RESPONSE in Opposition re 39 MOTION for More Definite Statement, 37 MOTION to Strike Response filed by John Doe.Reply to Response to Motion due by 7/29/2013 (Attachments: # 1 Memo in Support Memorandum of Law, # 2 State Court Documents Exhibit 1 - SCDSS Answer, # 3 Exhibit Exhibit 2 - E-mail Correspondence with Defendant, # 4 State Court Documents Exhibit 3 - Motion to Appoint GAL, # 5 Exhibit Exhibit 4 - Correspondence with Defendant, # 6 Exhibit Exhibit 5 - Case Law - Ransom v. VFS, # 7 Exhibit Exhibit 6 - Case Law - TM, LLC v. Anderson)(Butcher, Robert) (Entered: 07/19/2013)

1 Memo in Support Memorandum of Law

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2 State Court Documents Exhibit 1 - SCDSS Answer

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3 Exhibit Exhibit 2 - E-mail Correspondence with Defendant

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4 State Court Documents Exhibit 3 - Motion to Appoint GAL

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5 Exhibit Exhibit 4 - Correspondence with Defendant

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6 Exhibit Exhibit 5 - Case Law - Ransom v. VFS

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7 Exhibit Exhibit 6 - Case Law - TM, LLC v. Anderson

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RESPONSE in Opposition re 38 MOTION to Strike, 40 MOTION for More Definite Statement Response filed by John Doe.Reply to Response to Motion due by 7/29/2013 (Attachments: # 1 Memo in Support Memorandum of Law, # 2 State Court Documents Exhibit 1 - Defendant's Answer, # 3 Exhibit Exhibit 2 - E-mail Correspondence with Defendant, # 4 State Court Documents Exhibit 3 - Motion to Appoint GAL, # 5 Exhibit Exhibit 4 - Correspondence with Defendant, # 6 Exhibit Exhibit 5 - Case Law - Ransom v. VFS, # 7 Exhibit Exhibit 6 - Case Law - TM, LLC v. Anderson)(Butcher, Robert) (Entered: 07/19/2013)

1 Memo in Support Memorandum of Law

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2 State Court Documents Exhibit 1 - Defendant's Answer

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3 Exhibit Exhibit 2 - E-mail Correspondence with Defendant

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4 State Court Documents Exhibit 3 - Motion to Appoint GAL

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5 Exhibit Exhibit 4 - Correspondence with Defendant

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6 Exhibit Exhibit 5 - Case Law - Ransom v. VFS

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7 Exhibit Exhibit 6 - Case Law - TM, LLC v. Anderson

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REPLY to Response to Motion re 37 MOTION to Strike, 39 MOTION for More Definite Statement Response filed by Department of Social Services. (Logan, James) (Main Document 70 replaced on 7/30/2013) (alew, ). Modified on 7/30/2013 to replace with corrected document provided by filing user (alew, ). (Entered: 07/29/2013)

REPLY to Response to Motion re 38 MOTION to Strike, 40 MOTION for More Definite Statement Response filed by Ursula Best, Cassandra Daniels, Robin Kubler, Merry Eve Poole. (Logan, James) (Main Document 71 replaced on 7/30/2013) (alew, ). Modified on 7/30/2013 to replace with corrected document provided by filing user(alew, ). (Entered: 07/29/2013)

ANSWER to Complaint by Johnny Jones. (Attachments: # 1 Certificate of Service)(Halio, Andrew) (Entered: 07/29/2013)

1 Certificate of Service

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Local Rule 26.01 Answers to Interrogatories by Johnny Jones. (Attachments: # 1 Certificate of Service)(Halio, Andrew) (Entered: 07/30/2013)

1 Certificate of Service

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DISCOVERY REPORT and LOCAL RULE 26.03 REPORT by John Doe.(Butcher, Robert) Modified on 8/13/2013: to add LR 26.03 (kmca). (Entered: 08/12/2013)

Defendants Local Rule 26.03 Answers to Interrogatories by Ursula Best, Cassandra Daniels, Department of Social Services, Robin Kubler, Merry Eve Poole, Boys Home of the South Inc, Vernon Hayes, Nicole Lindsey, Cynthia Brock, Richelle Owens, Johnny Jones, Lillian Koller Isabel Blanco, Nikki Haley, Donna Outen, Robert Seepersaud, Patricia Boswell, Debra Wise, Charlene Robinson, Kathleen Hayes, and Johnny Jones.(Logan, James) Modified on 8/13/2013: to add filers listed on document (kmca). (Entered: 08/12/2013)

MOTION for Confidentiality Order by John Doe. Response to Motion due by 8/29/2013. (Attachments: # 1 Memorandum of Law, # 2 Addendum Red-Line Against Proposed Confidentiality Order)Proposed order is being emailed to chambers with copy to opposing counsel.(Butcher, Robert) Modified on 8/13/2013: to remove duplicate text (kmca). (Entered: 08/12/2013)

1 Memorandum of Law

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2 Addendum Red-Line Against Proposed Confidentiality Order

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ORDER re 77 MOTION for Confidentiality Order filed by John Doe. Hearing set for Thursday, 8/29/2013 09:30 AM in G Ross Anderson Jr Court House, 315 S McDuffie St, Anderson before Honorable G Ross Anderson Jr for the court to consider both parties' requests for confidentiality orders and amended scheduling orders. Signed by Honorable G Ross Anderson, Jr on 8/14/13. (alew, ) (Entered: 08/14/2013)

NOTICE of Hearing on Requests for Confidentiality Orders and Amended Scheduling Orders :Hearing set for Thursday, 8/29/2013 09:30 AM in G Ross Anderson Jr Court House, 315 S McDuffie St, Anderson before Honorable G Ross Anderson Jr. (alew, ) Modified on 8/14/2013 to edit text(alew, ). (Entered: 08/14/2013)

MOTION for Confidentiality Order by Ursula Best, Cassandra Daniels, Department of Social Services, Robin Kubler, Merry Eve Poole, Debra Wise, Robert Seepersaud, Charlene Robinson, Richelle Owens, Donna D Outen, Nicole Lindsey, Lillian Koller, Johnny Jones, Vernon Hayes, Kathleen Hayes, Nikki Haley, Cynthia Brock, Boys Home of the South Inc, Patricia Boswell, Isabel Blanco. Response to Motion due by 9/3/2013. (Attachments: # 1 Proposed Order Red-lined Confidentiality Order, # 2 Proposed Order Defendants' Proposed Confidentiality Order)No proposed order.(Logan, James) Modified on 8/15/2013 to add filers listed on document(alew, ). (Entered: 08/14/2013)

1 Proposed Order Red-lined Confidentiality Order

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2 Proposed Order Defendants' Proposed Confidentiality Order

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RESPONSE in Opposition re 77 MOTION for Confidentiality Order Response filed by Ursula Best, Isabel Blanco, Patricia Boswell, Boys Home of the South Inc, Cynthia Brock, Cassandra Daniels, Department of Social Services, Nikki Haley, Kathleen Hayes, Vernon Hayes, Johnny Jones, Lillian Koller, Robin Kubler, Nicole Lindsey, Donna D Outen, Richelle Owens, Merry Eve Poole, Charlene Robinson, Robert Seepersaud, Debra Wise.Reply to Response to Motion due by 9/6/2013 (Logan, James) (Entered: 08/26/2013)

Minute Entry. Proceedings held before Honorable G Ross Anderson, Jr: taking under advisement 77 Motion for Confidentiality Order; taking under advisement 80 Motion for Confidentiality Order. Order from the court forthcoming. Nothing due from counsel. Motion Hearing held on 8/29/2013. Court Reporter Jean Cole. (pbri, ) (Entered: 08/29/2013)

DELETION OF DOCKET ENTRY NUMBER 84 Reason: per judge's preferences, document should not have been filed. (alew, ) (Entered: 09/05/2013)

OPINION AND ORDER on Motions for Entry of Scheduling and Confidentiality Orders: denying 77 Motion for Confidentiality Order; denying 80 Motion for Confidentiality Order. Signed by Honorable G Ross Anderson, Jr on 9/5/13.(alew, ) (Entered: 09/05/2013)

CONFIDENTIALITY ORDER as set out. Signed by Honorable G Ross Anderson, Jr on 9/5/13. (alew, ) (Entered: 09/05/2013)

MOTION to Amend/Correct 60 Scheduling Order,, by John Doe. Response to Motion due by 10/11/2013. Proposed order is being emailed to chambers with copy to opposing counsel.(Butcher, Robert) (Entered: 09/24/2013)

AMENDED SCHEDULING ORDER as to Expert Disclosures: Plaintiffs ID of Expert Witness due by 10/16/2013,, Defendants ID of Expert Witnesses Due by 11/13/2013. Motion granted: 87 MOTION to Amend/Correct 60 Scheduling Order, filed by John Doe. Signed by Honorable G Ross Anderson, Jr on 9/25/13. (alew, ) (Entered: 09/25/2013)

PLAINTIFF'S ID OF EXPERT WITNESSES by John Doe.(Butcher, Robert) (Entered: 09/25/2013)

MOTION to Appear Pro Hac Vice by Aaron H. Finch ( Filing fee $ 250 receipt number 0420-4967337) by John Doe. Response to Motion due by 10/21/2013. (Attachments: # 1 Exhibit Pro Hac Vice Application, # 2 Exhibit Certificate of Good Standing)Proposed order is being emailed to chambers with copy to opposing counsel.(Butcher, Robert) (Entered: 10/02/2013)

1 Exhibit Pro Hac Vice Application

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2 Exhibit Certificate of Good Standing

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MOTION to Appear Pro Hac Vice by Kathryn A. Wood ( Filing fee $ 250 receipt number 0420-4967378) by John Doe. Response to Motion due by 10/21/2013. (Attachments: # 1 Exhibit Pro Hac Vice Application, # 2 Exhibit Certificate of Good Standing)Proposed order is being emailed to chambers with copy to opposing counsel.(Butcher, Robert) (Entered: 10/02/2013)

1 Exhibit Pro Hac Vice Application

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2 Exhibit Certificate of Good Standing

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ORDER granting 90 Motion to Appear Pro Hac Vice as to Aaron Finch for plaintiff John Doe. Signed by Honorable G Ross Anderson, Jr on 10/3/13.(alew, ) (Entered: 10/03/2013)

ORDER granting 91 Motion to Appear Pro Hac Vice as to Kathryn Wood for plaintiff John Doe. Signed by Honorable G Ross Anderson, Jr on 10/3/13.(alew, ) (Entered: 10/03/2013)

PLAINTIFF'S ID OF EXPERT WITNESSES Dr. Goetz by John Doe.(Butcher, Robert) (Entered: 10/16/2013)

MOTION to Amend/Correct 88 Scheduling Order, 60 Scheduling Order, by John Doe. Response to Motion due by 11/4/2013. Proposed order is being emailed to chambers with copy to opposing counsel.(Butcher, Robert) Modified on 10/17/2013 to edit text (alew, ). (Entered: 10/16/2013)

ORDER denying 96 Motion to Amend/Correct 60, 88 Scheduling Order. Signed by Honorable G Ross Anderson, Jr on 10/18/13.(alew, ) (Entered: 10/18/2013)

Joint MOTION for Protective Order and Quash Subpoenas by Ursula Best, Isabel Blanco, Patricia Boswell, Boys Home of the South Inc, Cynthia Brock, Cassandra Daniels, Department of Social Services, Nikki Haley, Kathleen Hayes, Vernon Hayes, Johnny Jones, Lillian Koller, Robin Kubler, Nicole Lindsey, Donna D Outen, Richelle Owens, Merry Eve Poole, Charlene Robinson, Robert Seepersaud, Debra Wise. Response to Motion due by 11/12/2013. (Attachments: # 1 Memo in Support, # 2 Exhibit A - Redacted Subpoenas, # 3 Exhibit B - Email from Plaintiff's Counsel, # 4 Exhibit C - Redacted Objection Letters to Subpoenas, # 5 Exhibit D - Redacted Interrogatory Responses by Plaintiff)No proposed order.(Wlodarczyk, Damon). Added MOTION to Quash Subpoenas on 10/28/2013; modified to add motion relief(alew, ). (Entered: 10/25/2013)

1 Memo in Support

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2 Exhibit A - Redacted Subpoenas

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3 Exhibit B - Email from Plaintiff's Counsel

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4 Exhibit C - Redacted Objection Letters to Subpoenas

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5 Exhibit D - Redacted Interrogatory Responses by Plaintiff

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PLAINTIFF'S ID OF EXPERT WITNESSES Vander Kolk and Reavis by John Doe.(Butcher, Robert) (Entered: 10/25/2013)

DEFENDANT'S ID OF EXPERT WITNESSES by Boys Home of the South Inc, Cynthia Brock, Vernon Hayes, Nicole Lindsey, Richelle Owens.(Gerrald, Matthew) (Entered: 10/25/2013)

DEFENDANT'S ID OF EXPERT WITNESSES by Ursula Best, Cassandra Daniels, Department of Social Services, Robin Kubler, Merry Eve Poole.(Logan, James) (Entered: 10/25/2013)

NOTICE of Appearance by Melissa Memolo Nichols on behalf of Julie Valentine Center (Nichols, Melissa) (Main Document 103 replaced on 10/29/2013) (alew, ). Modified on 10/29/2013 to replace with corrected document provided by filing user(alew, ). (Entered: 10/28/2013)

NOTICE of Hearing on Motion 98 Joint MOTION for Protective Order and Quash Subpoenas MOTION to Quash : Motion Hearing set for Monday, 11/25/2013 10:15 AM in G Ross Anderson Jr Court House, 315 S McDuffie St, Anderson before Honorable G Ross Anderson Jr. (alew, ) (Entered: 10/31/2013)

PLAINTIFF'S ID OF EXPERT WITNESSES by John Doe.(Butcher, Robert) (Entered: 11/01/2013)

NOTICE OF FILING OF OFFICIAL TRANSCRIPT of Motion Hearing on Requests for Confidentiality Orders and Amended Scheduling Orders held on 08/29/2013, before Judge Honorable G. Ross Anderson. Court Reporter/Transcriber Jean L. Cole`, Telephone number/E-mail (864)350-1304 or email at jejocole@gmail.com. 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 it may be obtained through PACER or from the court reporter. Parties have 7 calendar days from the filing of the transcript to file with the court a Notice of Intent to Request Redaction.. Redaction Request due 11/25/2013. Redacted Transcript Deadline set for 12/5/2013. Release of Transcript Restriction set for 2/3/2014. (jcole, ) (Entered: 11/04/2013)

MOTION for Protective Order, MOTION to Quash ( Response to Motion due by 11/25/2013.) by Julie Valentine Center. (Attachments: # 1 Memo in Support)No proposed order.(Nichols, Melissa) (Entered: 11/07/2013)

1 Memo in Support

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RESPONSE in Opposition re 98 Joint MOTION for Protective Order and Quash Subpoenas MOTION to Quash Response filed by John Doe.Reply to Response to Motion due by 11/18/2013 (Attachments: # 1 Affidavit Declaration of Robert Butcher with Exhibits A and B)(Butcher, Robert) (Entered: 11/08/2013)

1 Affidavit Declaration of Robert Butcher with Exhibits A and B

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REVISED NOTICE of Hearing on Motion 107 MOTION for Protective Order MOTION to Quash, 98 Joint MOTION for Protective Order and Quash Subpoenas MOTION to Quash : Motion Hearing set for 11/25/2013 10:15 AM in G Ross Anderson Jr Court House, 315 S McDuffie St, Anderson before Honorable G Ross Anderson Jr. (alew, ) (Entered: 11/12/2013)

DEFENDANT'S ID OF EXPERT WITNESSES by Ursula Best, Boys Home of the South Inc, Cynthia Brock, Cassandra Daniels, Department of Social Services, Vernon Hayes, Johnny Jones, Robin Kubler, Nicole Lindsey, Richelle Owens, Merry Eve Poole.(Logan, James) (Entered: 11/13/2013)

MOTION to Appear Pro Hac Vice by Laurence Borten ( Filing fee $ 250 receipt number 0420-5047604) by John Doe. Response to Motion due by 12/9/2013. (Attachments: # 1 Affidavit Pro Hac Vice Application)Proposed order is being emailed to chambers with copy to opposing counsel.(Butcher, Robert) (Additional attachment(s) added on 11/20/2013: # 2 Certificate of Good Standing-Laurence D. Borten) (alew, ). Modified on 11/20/2013 to add document provided by filing user(alew, ). (Entered: 11/20/2013)

1 Affidavit Pro Hac Vice Application

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2 Certificate of Good Standing-Laurence D. Borten

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MOTION to Appear Pro Hac Vice by Sarah Russo ( Filing fee $ 250 receipt number 0420-5047725) by John Doe. Response to Motion due by 12/9/2013. (Attachments: # 1 Affidavit Application for Pro Hac Vice, # 2 Exhibit Certificate of Good Standing)Proposed order is being emailed to chambers with copy to opposing counsel.(Butcher, Robert) (Entered: 11/20/2013)

1 Affidavit Application for Pro Hac Vice

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2 Exhibit Certificate of Good Standing

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NOTICE of Appearance by C Cliff Rollins on behalf of Patricia Boswell, Charlene Robinson, Debra Wise (Rollins, C) (Entered: 11/20/2013)

RESPONSE in Opposition re 107 MOTION for Protective Order MOTION to Quash Response filed by John Doe.Reply to Response to Motion due by 12/5/2013 (Butcher, Robert) (Entered: 11/21/2013)

ORDER granting 111 Motion to Appear Pro Hac Vice as to Laurence Drew Borten for plaintiff. Signed by Honorable G Ross Anderson, Jr on 11/22/13.(alew, ) (Entered: 11/22/2013)

ORDER granting 112 Motion to Appear Pro Hac Vice as to Sarah Teresa Russo for plaintiff. Signed by Honorable G Ross Anderson, Jr on 11/22/13.(alew, ) (Entered: 11/22/2013)

Minute Entry. Proceedings held before Honorable G Ross Anderson, Jr: Motion Hearing held on 11/25/2013 re 98 Joint MOTION for Protective Order and Quash Subpoenas MOTION to Quash filed by defendants 107 and MOTION for Protective Order. Counsel to remedy their discovery and reduction issues. Court declines ruling at this time. Court Reporter Judy Johnson. (pbri, ) (Entered: 11/25/2013)

MOTION to Exclude Certain Witnesses Identified by the Plaintiff by Boys Home of the South Inc, Cynthia Brock, Vernon Hayes, Nicole Lindsey, Richelle Owens. Response to Motion due by 12/12/2013. No proposed order.(Dowling, Curtis) (Entered: 11/25/2013)

ORDER granting 98 Motion for Protective Order; granting 98 Motion to Quash; granting 107 Motion for Protective Order; granting 107 Motion to Quash Signed by Honorable G Ross Anderson, Jr on 11/25/13.(alew, ) (Entered: 11/25/2013)

MOTION to Exclude Certain Expert Witnesses Identified by the Plaintiff by Ursula Best, Isabel Blanco, Patricia Boswell, Boys Home of the South Inc, Cynthia Brock, Cassandra Daniels, Department of Social Services, Nikki Haley, Kathleen Hayes, Vernon Hayes, Johnny Jones, Lillian Koller, Robin Kubler, Nicole Lindsey, Donna D Outen, Richelle Owens, Merry Eve Poole, Charlene Robinson, Robert Seepersaud, Debra Wise. Response to Motion due by 12/13/2013. No proposed order.(Dowling, Curtis) (Entered: 11/26/2013)

RESPONSE in Opposition re 118 MOTION to Exclude Certain Witnesses Identified by the Plaintiff Response filed by John Doe.Reply to Response to Motion due by 12/23/2013 (Attachments: # 1 Exhibit A - Plaintiff's Responses and Objections to BHOTS's First Interrogatories, # 2 Exhibit B - Plaintiff's Responses and Objections to SCDSS's First Interrogatories, # 3 Exhibit C - Plaintiff's First Supplemental Responses and Objections to SCDSS's First Interrogatories)(Butcher, Robert) Modified on 12/13/2013: to remove duplicate text (kmca). (Attachment 1 replaced on 12/20/2013) (alew, ). (Attachment 2 replaced on 12/20/2013) (alew, ). Modified on 12/20/2013 to replace with redacted documents per attorney request(alew, ). (Entered: 12/12/2013)

1 Exhibit A - Plaintiff's Responses and Objections to BHOTS's Fi

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2 Exhibit B - Plaintiff's Responses and Objections to SCDSS's Fi

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3 Exhibit C - Plaintiff's First Supplemental Responses and Objections

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RESPONSE in Opposition re 120 MOTION to Exclude Certain Expert Witnesses Identified by the Plaintiff Response filed by John Doe.Reply to Response to Motion due by 12/23/2013 (Butcher, Robert) (Entered: 12/13/2013)

STIPULATION of Dismissal With Prejudice (Defendant Haley) by Nikki Haley, Debra Wise, Robert Seepersaud, Charlene Robinson, Merry Eve Poole, Richelle Owens, Donna D. Outen, Nicole Lindsey, Robin Kubler, Lillian Koller, Julie Valentine Center, Johnny Jones, Vernon Hayes, Kathleen Hayes, John Doe, Department of Social Services, Cassandra Daniels, Cynthia Brock, Boys Home of the South Inc, Patricia Boswell, Isable Blanco, Ursula Best, (Woodington, Kenneth) Modified on 12/20/2013 to add filers listed on document (alew, ). (Entered: 12/17/2013)

MOTION for Discovery Mental Examination of the Plaintiff by Ursula Best, Boys Home of the South Inc, Cynthia Brock, Cassandra Daniels, Department of Social Services, Vernon Hayes, Johnny Jones, Robin Kubler, Nicole Lindsey, Richelle Owens, Merry Eve Poole. Response to Motion due by 1/3/2014. Proposed order is being emailed to chambers with copy to opposing counsel.(Dowling, Curtis) (Entered: 12/17/2013)

RESPONSE in Opposition re 125 MOTION for Discovery Mental Examination of the Plaintiff Response filed by John Doe.Reply to Response to Motion due by 12/30/2013 (Attachments: # 1 Exhibit 1 - Letter from Dr. Goetz, # 2 Exhibit 2 - E-Mail from Defendants, # 3 Exhibit 3 - Letter from Lindler, # 4 Exhibit 4 - I.L. Statement, # 5 Exhibit 5 - BHOTS Discharge Summary, # 6 Exhibit 6 - Case Law - Hirschheimer v. Asso Metals and Minerals Corp, # 7 Exhibit 7 - Deposition of John Doe, # 8 Exhibit 8 - Burger v. Litton Industries)(Butcher, Robert) (Attachment 3 replaced on 12/20/2013) (alew, ). Modified on 12/20/2013 to replace with exhibit per attorney request, to edit text(alew, ). (Entered: 12/20/2013)

1 Exhibit 1 - Letter from Dr. Goetz

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2 Exhibit 2 - E-Mail from Defendants

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3 Exhibit 3 - Letter from Lindler

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4 Exhibit 4 - I.L. Statement

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5 Exhibit 5 - BHOTS Discharge Summary

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6 Exhibit 6 - Case Law - Hirschheimer v. Asso Metals and Minerals Corp

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7 Exhibit 7 - Deposition of John Doe

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8 Exhibit 8 - Burger v. Litton Industries

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