Case: Cliatt v. United States

Cliatt v. United States of America et al.

COMPLAINT with Jury Demand filed by Hilliard Toi Cliatt. (Filing fee $400, receipt number AGANDC- 8940199) (Attachments: # 1 Civil Cover Sheet) (jed) 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: 09/18/2019)

Summons Issued as to United States of America and Lawrence Guerra by U.S. Attorney. (Attachments: # 1 Summons) (jed) (Entered: 09/18/2019)

STANDING ORDER REGARDING CIVIL LITIGATION. Signed by Judge J. P. Boulee on 9/18/19. (bnw) (Entered: 09/18/2019)

Ex Parte MOTION for Discovery with Brief In Support by Hilliard Toi Cliatt. (Attachments: # 1 Text of Proposed Order)(Greenamyre, Zack) (Entered: 10/08/2019)

Ex Parte MOTION for Service on unknown agents and for notification of pendency of action with Brief In Support by Hilliard Toi Cliatt. (Attachments: # 1 Text of Proposed Order)(Greenamyre, Zack) (Entered: 10/08/2019)

RESPONSE re 4 Ex Parte MOTION for Discovery filed by United States of America. (Williams, Samuel) (Entered: 10/22/2019)

RESPONSE re 5 Ex Parte MOTION for Service on unknown agents and for notification of pendency of action filed by United States of America. (Williams, Samuel) (Entered: 10/22/2019)

Submission of 4 Ex Parte MOTION for Discovery, 5 Ex Parte MOTION for Service on unknown agents and for notification of pendency of action, to District Judge J. P. Boulee. (ddm)

Request for Leave of Absence for the following date(s): February 3-7, 2020; March 25-April 1, 2020; August 37, 2020, by Zack Greenamyre. (Greenamyre, Zack) (Entered: 11/11/2019)

ORDER denying Plaintiff's Motion for Order of Service of the Complaint on Unknown Agents [Doc. 5] and granting in part and denying in part Plaintiff's Ex Parte Motion for Limited, Expedited Early Discovery to Identify Unknown Agents [Doc. 4]. Plaintiff shall be permitted limited written discovery for the sole purpose of identifying the John Doe defendants. Specifically, Plaintiff may serve a single interrogatory on Defendant United States that requests the names of the John Doe defendants. Signed by Judge J. P. Boulee on 11/25/19. (ddm) (Entered: 11/25/2019)

CERTIFICATE OF SERVICE of Plaintiff's First Interrogatory to Defendant United States of America by Hilliard Toi Cliatt.(Greenamyre, Zack) (Entered: 11/25/2019)

Unopposed MOTION for Extension of Time to File Answer with Brief In Support by Lawrence Guerra, United States of America. (Attachments: # 1 Brief Memorandum of Law in Support, # 2 Text of Proposed Order)(Williams, Samuel) (Entered: 11/27/2019)

ORDER granting 11 Defendant's Unopposed Motion for Extension of Time, through December 23, 2019, to respond to 1 Plaintiff's Complaint. Signed by Judge J. P. Boulee on 12/3/19. (ddm) (Entered: 12/03/2019)

ANSWER to 1 COMPLAINT by United States of America. Discovery ends on 5/19/2020.(Williams, Samuel) Please visit our website at http://www.gand.uscourts.gov to obtain Pretrial Instructions. (Entered: 12/21/2019)

MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM with Brief In Support by Lawrence Guerra. (Attachments: # 1 Brief, # 2 Exhibit Exhibit A)(Williams, Samuel) (Entered: 12/21/2019)

MOTION for Order to Stay Discovery with Brief In Support by Lawrence Guerra. (Attachments: # 1 Brief)(Williams, Samuel) (Entered: 12/23/2019)

Unopposed MOTION for Extension of Time Respond to Defendant Guerra's Motions to Dismiss and to Stay with Brief In Support by Hilliard Toi Cliatt. (Attachments: # 1 Text of Proposed Order)(Greenamyre, Zack) (Entered: 01/02/2020)

ORDER: The 16 motion is GRANTED. Plaintiff shall respond to Defendants' motions no later than January 13, 2020. Signed by Judge J. P. Boulee on 1/3/20. (bnw)

RESPONSE in Opposition re 14 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by Hilliard Toi Cliatt. (Attachments: # 1 Rule 56(d) Declaration of Counsel)(Greenamyre, Zack) (Entered: 01/13/2020)

RESPONSE in Opposition re 15 MOTION for Order to Stay Discovery filed by Hilliard Toi Cliatt. (Greenamyre, Zack) (Entered: 01/13/2020)

REPLY BRIEF re 14 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by Lawrence Guerra. (Williams, Samuel) (Entered: 01/27/2020)

REPLY BRIEF re 15 MOTION for Order to Stay Discovery filed by Lawrence Guerra. (Williams, Samuel) (Entered: 01/27/2020)

JOINT PRELIMINARY REPORT AND DISCOVERY PLAN filed by Hilliard Toi Cliatt. (Greenamyre, Zack) (Entered: 01/28/2020)

SCHEDULING ORDER regarding the parties' 21 Joint Preliminary Report and Discovery Plan. Initial disclosures shall not immediately be provided. In the event Defendants' Motion to Stay is denied, initial disclosures shall be filed within fourteen days of the denial. In the event the stay is granted, initial disclosures shall be filed within fourteen days of the opening of discovery. This case is assigned to a four-month discovery period. The discovery period does not begin, however, until this Court either denies Defendants' Motion to Stay Discovery, or if granted, upon the expiration of the stay. Signed by Judge J. P. Boulee on 1/29/2020. (ddm) (Entered: 01/29/2020)

Submission of 14 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM, 15 MOTION for Order to Stay Discovery, to District Judge J. P. Boulee. (ddm)

ORDER directing the parties to each file a Certificate of Interested Persons and Corporate Disclosure Statement within seven days from the date of entry of this order. Signed by Judge J. P. Boulee on 2/3/2020. (ddm) (Entered: 02/04/2020)

Certificate of Interested Persons by Hilliard Toi Cliatt. (Greenamyre, Zack) (Entered: 02/10/2020)

Certificate of Interested Persons by Lawrence Guerra. (Williams, Samuel) (Entered: 02/10/2020)

Certificate of Interested Persons by United States of America. (Williams, Samuel) (Entered: 02/10/2020)

Clerks Notation re 24 Certificate of Interested Persons approved by JPB. (bnw)

Clerks Notation re 25 26 Certificates of Interested Persons. (bnw)

General Order 20-01 re: COURT OPERATIONS UNDER THE EXIGENT CIRCUMSTANCES CREATED BY COVID-19 AND RELATED CORONA VIRUS. Signed by Judge Thomas W. Thrash, Jr. on 3/16/2020. (ddm) (Entered: 03/23/2020)

ORDER granting 15 Defendant Lawrence Guerra's Motion to Stay Discovery. Discovery in this matter is stayed until resolution of Defendant Guerra's Motion to Dismiss. Signed by Judge J. P. Boulee on 3/27/20202. (ddm) (Entered: 03/27/2020)

Amended General Order 20-01 re COURT OPERATIONS UNDER THE EXIGENT CIRCUMSTANCES CREATED BY COVID-19 AND RELATED CORONA VIRUS. Signed by Judge Thomas W. Thrash, Jr. on 3/30/20. (aaq) (ADI) (Entered: 04/02/2020)

SECOND AMENDMENT TO GENERAL ORDER 20-01 RE: COURT OPERATIONS UNDER THE EXIGENT CIRCUMSTANCES CREATED BY COVID-19 AND RELATED CORONA VIRUS. Signed by Judge Thomas W. Thrash, Jr. on 04/30/2020. (adg) (ADI) (Entered: 05/04/2020)

THIRD AMENDMENT TO GENERAL ORDER 20-01 RE: COURT OPERATIONS UNDER THE EXIGENT CIRCUMSTANCES CREATED BY COVID-19 AND RELATED CORONA VIRUS. Signed by Judge Thomas W. Thrash, Jr. on 05/26/2020. (jap) (ADI) (Entered: 05/27/2020)

NOTICE of Appearance by Aaron Joshua Ross on behalf of Lawrence Guerra, United States of America (Ross, Aaron) (Entered: 06/10/2020)

FOURTH AMENDMENT TO GENERAL ORDER 20-01 RE: COURT OPERATIONS UNDER THE EXIGENT CIRCUMSTANCES CREATED BY COVID-19 AND RELATED CORONA VIRUS. Signed by Judge Thomas W. Thrash, Jr. on 07/01/2020. (rvb) (ADI) (Entered: 07/02/2020)

FIFTH AMENDMENT TO GENERAL ORDER 20-01 RE: COURT OPERATIONS UNDER THE EXIGENT CIRCUMSTANCES CREATED BY COVID-19 AND RELATED CORONAVIRUS. Signed by Judge Thomas W. Thrash, Jr. on 7/10/2020 (adg) (ADI) (Entered: 07/13/2020)

SIXTH AMENDMENT TO GENERAL ORDER 20-01 RE: COURT OPERATIONS UNDER THE EXIGENT CIRCUMSTANCES CREATED BY COVID-19 AND RELATED CORONAVIRUS. Signed by Judge Thomas W. Thrash, Jr. on 08/03/2020. (aaq) (ADI) (Entered: 08/04/2020)

ORDER - The Court DENIES Guerra's motion for summary judgment without prejudice and grants Cliatt's motion for discovery. The stay on discovery entered by this Court on March 27, 2020, is hereby lifted, and discovery may proceed against all defendants as allowed under applicable law. Signed by Judge J. P. Boulee on 8/28/2020. (tcc) (Entered: 08/28/2020)

SEVENTH AMENDMENT TO GENERAL ORDER 20-01 RE: COURT OPERATIONS UNDER THE EXIGENT CIRCUMSTANCES CREATED BY COVID-19 AND RELATED CORONAVIRUS. Signed by Judge Thomas W. Thrash, Jr. on 9/1/2020. (mmc) (ADI) (Entered: 09/02/2020)

ANSWER to 1 COMPLAINT by Lawrence Guerra.(Ross, Aaron) Please visit our website at http://www.gand.uscourts.gov to obtain Pretrial Instructions. (Entered: 09/11/2020)

CERTIFICATE OF SERVICE of Plaintiff's initial disclosures by Hilliard Toi Cliatt.(Greenamyre, Zack) (Entered: 09/24/2020)

Initial Disclosures by Lawrence Guerra, United States of America.(Ross, Aaron) (Entered: 09/24/2020)

EIGHTH AMENDMENT TO GENERAL ORDER 20-01 RE: COURT OPERATIONS UNDER THE EXIGENT CIRCUMSTANCES CREATED BY COVID19 AND RELATED CORONA VIRUS. Signed by Judge Thomas W. Thrash, Jr. on 09/28/2020. (mmc) (ADI) (Entered: 09/29/2020)

CERTIFICATE OF SERVICE of Defendants' First Interrogatories, First Requests for Production, and First Requests for Admission to Plaintiff by Lawrence Guerra, United States of America.(Ross, Aaron) (Entered: 11/06/2020)

NINTH AMENDMENT TO GENERAL ORDER 20-01 RE: COURT OPERATIONS UNDER THE EXIGENT CIRCUMSTANCES CREATED BY COVID-19 AND RELATED CORONAVIRUS. Signed by Judge Thomas W. Thrash, Jr. on 12/08/2020. (mmc) (ADI) (Entered: 12/09/2020)

Joint MOTION for Extension of Time to Complete Discovery with Brief In Support by Lawrence Guerra, United States of America. (Attachments: # 1 Ex. A: Proposed Order)(Ross, Aaron) (Entered: 12/09/2020)

ORDER: For good cause shown, the 44 Joint Motion to Extend Discovery Period is GRANTED. IT IS HEREBY ORDERED that discovery is extended through and including March 29, 2021. Dispositive motions shall be filed no later than April 28, 2021. Absent compelling circumstances, future extensions are unlikely. Signed by Judge J. P. Boulee on 12/10/20. (bnw)

CERTIFICATE OF SERVICE by Hilliard Toi Cliatt.(Greenamyre, Zack) (Entered: 12/30/2020)

TENTH AMENDMENT TO GENERAL ORDER 20-01 RE: COURT OPERATIONS UNDER THE EXIGENT CIRCUMSTANCES CREATED BY COVID-19 AND RELATED CORONAVIRUS. Signed by Judge Thomas W. Thrash, Jr. on 01/27/2021. (mmc) (ADI) (Entered: 01/28/2021)

Joint MOTION for Protective Order with Brief In Support by United States of America. (Attachments: # 1 Protective Order)(Ross, Aaron) (Entered: 03/01/2021)

ORDER granting the parties' 47 Joint Motion for Protective Order. Signed by Judge J. P. Boulee on 3/2/2021. (ddm) (Entered: 03/02/2021)

NOTICE to Take Deposition of Defendant Guerra, FBI, Donovan, and Lemoine filed by Hilliard Toi Cliatt (Greenamyre, Zack) (Entered: 03/08/2021)

ELEVENTH AMENDMENT TO GENERAL ORDER 20-01 RE: COURT OPERATIONS UNDER THE EXIGENT CIRCUMSTANCES CREATED BY COVID-19 AND RELATED CORONAVIRUS. Signed by Judge Thomas W. Thrash, Jr. on 03/09/2021 (ddm) (ADI) (Entered: 03/10/2021)

Unopposed MOTION for Extension of Time to Complete Discovery with Brief In Support by United States of America. (Attachments: # 1 Ex. A: Proposed Order)(Ross, Aaron) (Entered: 03/11/2021)

NOTICE to Take Deposition of Hilliard Toi Cliatt filed by Lawrence Guerra, United States of America (Ross, Aaron) (Entered: 03/11/2021)

NOTICE to Take Deposition of Curtrina Martin filed by Lawrence Guerra, United States of America (Ross, Aaron) (Entered: 03/11/2021)

ORDER granting in part the 51 United States of America's Unopposed Motion to Extend Discovery Period. Discovery is extended through and including April 13, 2021. No later than March 26, 2021, Defendant shall complete its rolling production of documents. Dispositive motions shall be filed no later than May 4, 2021. Future extensions are unlikely. Signed by Judge J. P. Boulee on 3/17/2021. (ddm) (Entered: 03/17/2021)

Amended NOTICE to Take Deposition of Guerra and others filed by Hilliard Toi Cliatt (Greenamyre, Zack) (Entered: 03/31/2021)

Joint MOTION to Bifurcate discovery as to damages by Hilliard Toi Cliatt. (Attachments: # 1 Text of Proposed Order)(Greenamyre, Zack) (Entered: 04/02/2021)

ORDER: For good cause shown, the 56 Joint Motion for Amended Scheduling Order is GRANTED. IT IS HEREBY ORDERED that within forty days of the denial of summary judgment, the parties shall take the depositions of Plaintiff's medical providers. Signed by Judge J. P. Boulee on 4/2/21. (bnw)

MOTION for Extension of Time to Complete Discovery by Hilliard Toi Cliatt. (Attachments: # 1 Text of Proposed Order)(Greenamyre, Zack) (Entered: 04/13/2021)

NOTICE by Hilliard Toi Cliatt CONSOLIDATED/JOINT DISCOVERY STATEMENT OF DISCOVERY DISPUTE (Greenamyre, Zack) (Entered: 04/13/2021)

RESPONSE re 57 MOTION for Extension of Time to Complete Discovery filed by Lawrence Guerra, United States of America. (Ross, Aaron) (Entered: 04/14/2021)

Unopposed MOTION for Extension of Time to File Summary Judgment Motions, Unopposed MOTION for Leave to File Excess Pages for Summary Judgment Briefs with Brief In Support by Lawrence Guerra, United States of America. (Attachments: # 1 Ex. A: Proposed Order)(Ross, Aaron) (Entered: 04/23/2021)

ORDER: For good cause shown, Defendants' 60 Unopposed Motion is GRANTED. IT IS HEREBY ORDERED that Defendants' deadline to file dispositive motions is extended through and including May 14, 2021. IT IS FURTHER ORDERED that Defendants are permitted to file a brief in support of their motion for summary judgment that is up to thirty-five pages in length. Signed by Judge J. P. Boulee on 4/26/21. (bnw)

Submission of 57 MOTION for Extension of Time to Complete Discovery, to District Judge J. P. Boulee. (ddm)

NOTICE of TELECONFERENCE Hearing: Discovery Hearing set for 5/5/2021 at 02:00 PM before Judge J. P. Boulee. (bnw)

Minute Entry for proceedings held before Judge J. P. Boulee: Discovery Hearing held on 5/5/2021. See transcript for more details. (Court Reporter Penny Coudriet)(ddm) (Entered: 05/06/2021)

ORDER: IT IS HEREBY ORDERED that Plaintiff's 57 Motion to Extend Discovery is GRANTED. Discovery is extended through and including May 28, 2021. Dispositive motions are due June 14, 2021. Signed by Judge J. P. Boulee on 5/7/21. (bnw)

NOTICE to Take Deposition of Bazzell and Murdock filed by Hilliard Toi Cliatt (Greenamyre, Zack) (Entered: 05/11/2021)

MOTION for Order approving leave of absence by Hilliard Toi Cliatt. (Attachments: # 1 Text of Proposed Order)(Greenamyre, Zack) (Entered: 05/13/2021)

ORDER: IT IS HEREBY ORDERED that Zack Greenamyre, counsel for Plaintiff, is hereby granted a leave of absence for the periods from August 9 through September 20, 2021. Signed by Judge J. P. Boulee on 5/13/21. (bnw)

Request for Leave of Absence for the following date(s): June 14-18, 2021, November 11-12, 2021, November 15, 2021, by Aaron Joshua Ross. (Ross, Aaron) (Entered: 05/28/2021)

NOTICE by Hilliard Toi Cliatt Second Consolidated/Joint Discovery Statement of Discovery Dispute (Greenamyre, Zack) (Entered: 05/28/2021)

NOTICE OF VIDEO PROCEEDING : Discovery Hearing set for 7/7/2021 at 02:00 PM before Judge J. P. Boulee. Connection Instructions: Join ZoomGov Meeting https://ganduscourts.zoomgov.com/j/1605284642 Meeting ID: 160 528 4642 Passcode: 343482 One tap mobile +16692545252 You must follow the instructions of the Court for remote proceedings available here. The procedure for filing documentary exhibits admitted during the proceeding is available here. Photographing, recording, or broadcasting of any judicial proceedings, including proceedings held by video teleconferencing or telephone conferencing, is strictly and absolutely prohibited. (bnw)

NOTICE OF CANCELLATION of Hearing re: NOTICE OF VIDEO PROCEEDING : Discovery Hearing set for 7/7/2021 at 02:00 PM before Judge J. P. Boulee. Connection Instructions: Join ZoomGov Meeting https://ganduscourts.zoomgov.com/j/1605284642 Meeting ID: 160 528 4642 Passcode: 343482 One tap mobile +16692545252 You must follow the instructions of the Court for remote proceedings available here. The procedure for filing documentary exhibits admitted during the proceeding is available here. Photographing, recording, or broadcasting of any judicial proceedings, including proceedings held by video teleconferencing or telephone conferencing, is strictly and absolutely prohibited. (bnw) (bnw)

NOTICE OF VIDEO PROCEEDING : Discovery Hearing set for 7/14/2021 at 10:00 AM before Judge J. P. Boulee. Connection Instructions: Join ZoomGov Meeting https://ganduscourts.zoomgov.com/j/1605284642 Meeting ID: 160 528 4642 Passcode: 343482 One tap mobile +16692545252 You must follow the instructions of the Court for remote proceedings available here. The procedure for filing documentary exhibits admitted during the proceeding is available here. Photographing, recording, or broadcasting of any judicial proceedings, including proceedings held by video teleconferencing or telephone conferencing, is strictly and absolutely prohibited. (bnw)

NOTICE OF CANCELLATION of Hearing re: NOTICE OF VIDEO PROCEEDING : Discovery Hearing set for 7/14/2021 at 10:00 AM before Judge J. P. Boulee. Connection Instructions: Join ZoomGov Meeting https://ganduscourts.zoomgov.com/j/1605284642 Meeting ID: 160 528 4642 Passcode: 343482 One tap mobile +16692545252 You must follow the instructions of the Court for remote proceedings available here. The procedure for filing documentary exhibits admitted during the proceeding is available here. Photographing, recording, or broadcasting of any judicial proceedings, including proceedings held by video teleconferencing or telephone conferencing, is strictly and absolutely prohibited. (bnw) (bnw)

NOTICE OF VIDEO PROCEEDING : Discovery Hearing set for 7/13/2021 at 03:00 PM before Judge J. P. Boulee. Connection Instructions: Join ZoomGov Meeting https://ganduscourts.zoomgov.com/j/1605284642 Meeting ID: 160 528 4642 Passcode: 343482 One tap mobile +16692545252 You must follow the instructions of the Court for remote proceedings available here. The procedure for filing documentary exhibits admitted during the proceeding is available here. Photographing, recording, or broadcasting of any judicial proceedings, including proceedings held by video teleconferencing or telephone conferencing, is strictly and absolutely prohibited. (bnw)

Minute Entry for proceedings held before Judge J. P. Boulee: Discovery Hearing held on 7/13/2021. The Court directed the followingdeadlines: Motion for Summary Judgment due 8/27/21; Response due 9/10/21;Reply due 9/21/21. Hearing Concluded. (Court Reporter Lori Burgess)(adg) (Entered: 07/14/2021)

NOTICE to Take Deposition of Guerra filed by Hilliard Toi Cliatt (Greenamyre, Zack) (Entered: 07/19/2021)

Amended NOTICE to Take Deposition of Lawrence Guerra filed by Hilliard Toi Cliatt (Greenamyre, Zack) (Entered: 07/27/2021)

MOTION for Summary Judgment with Brief In Support by Lawrence Guerra, United States of America. (Attachments: # 1 Memorandum of Law in Support, # 2 Ex. A - Cliatt Deposition Excerpts, # 3 Ex. B - Martin Deposition Excerpts, # 4 Ex. C - Guerra Deposition I Excerpts, # 5 Ex. D - Thompson Deposition Excerpts, # 6 Ex. E - Crum Declaration, # 7 Ex. F - Bazzell Deposition Excerpts, # 8 Ex. G - Guerra Deposition II Excerpts, # 9 Ex. H - Lemoine Deposition Excerpts, # 10 Ex. I - Donovan Deposition Excerpts, # 11 Ex. J - Martin RFA Responses, # 12 Ex. K - Burke Deposition Excerpts, # 13 Ex. L - Dye Deposition Excerpts, # 14 Ex. M - Fehmel Deposition Excerpts, # 15 Ex. N - McGee Declaration, # 16 Ex. O - Pettry Deposition Excerpts, # 17 Statement of Undisputed Material Facts)(Ross, Aaron) --Please refer to http://www.gand.uscourts.gov to obtain the Notice to Respond to Summary Judgment Motion form contained on the Court's website.-- (Entered: 08/27/2021)

NOTICE Of Filing Exhibit 1 to McGee Declaration by Lawrence Guerra, United States of America (Ross, Aaron) Modified on 9/3/2021. One (1) DVD received, scanned by JM in systems, and placed in file. (tcc) (Entered: 08/27/2021)

SEALED DEPOSITION of Hilliard Toi Cliatt taken on March 22, 2021 by Lawrence Guerra, United States of America.(Ross, Aaron) Modified to reflect sealed on 8/30/2021 (ceo). (Entered: 08/27/2021)

SEALED DEPOSITION of Curtrina Martin taken on March 24, 2021 by Lawrence Guerra, United States of America.(Ross, Aaron) Modified to reflect sealed on 8/30/2021 (ceo). (Entered: 08/27/2021)

SEALED DEPOSITION of Lawrence Guerra taken on March 31, 2021 by Lawrence Guerra, United States of America.(Ross, Aaron) Modified to reflect sealed on 8/30/2021 (ceo). (Entered: 08/27/2021)

SEALED DEPOSITION of Joshua Thompson taken on April 8, 2021 by Lawrence Guerra, United States of America.(Ross, Aaron) Modified to reflect sealed on 8/30/2021 (ceo). (Entered: 08/27/2021)

SEALED DEPOSITION of Jennifer Bazzell taken on May 17, 2021 by Lawrence Guerra, United States of America.(Ross, Aaron) Modified to reflect sealed on 8/30/2021 (ceo). (Entered: 08/27/2021)

SEALED DEPOSITION of Lawrence Guerra taken on August 4, 2021 by Lawrence Guerra, United States of America.(Ross, Aaron) Modified to reflect sealed on 8/30/2021 (ceo). (Entered: 08/27/2021)

SEALED DEPOSITION of Michael Lemoine taken on April 6, 2021 by Lawrence Guerra, United States of America.(Ross, Aaron) Modified to reflect sealed on 8/30/2021 (ceo). (Entered: 08/27/2021)

SEALED DEPOSITION of Gregory Donovan taken on April 5, 2021 by Lawrence Guerra, United States of America.(Ross, Aaron) Modified to reflect sealed on 8/30/2021 (ceo). (Entered: 08/27/2021)

SEALED DEPOSITION of Timothy Burke taken on April 13, 2021 by Lawrence Guerra, United States of America.(Ross, Aaron) Modified to reflect sealed on 8/30/2021 (ceo). (Entered: 08/27/2021)

SEALED DEPOSITION of Douglas Dye taken on April 9, 2021 by Lawrence Guerra, United States of America.(Ross, Aaron) Modified to reflect sealed on 8/30/2021 (ceo). (Entered: 08/27/2021)

SEALED DEPOSITION of Tim Fehmel taken on April 13, 2021 by Lawrence Guerra, United States of America.(Ross, Aaron) Modified to reflect sealed on 8/30/2021 (ceo). (Entered: 08/27/2021)

SEALED DEPOSITION of Michael Pettry taken on April 7, 2021 by Lawrence Guerra, United States of America.(Ross, Aaron) Modified to reflect sealed on 8/30/2021 (ceo). (Entered: 08/27/2021)

Unopposed MOTION for Leave to File Matters Under Seal re: 71 Deposition, 72 Deposition, 82 Deposition, 81 Deposition, 80 Deposition, 79 Deposition, 74 Deposition, 73 Deposition, 76 Deposition, 77 Deposition, 75 Deposition, 78 Deposition with Brief In Support by Lawrence Guerra, United States of America. (Attachments: # 1 Memorandum of Law in Support, # 2 Ex. A: Proposed Order)(Ross, Aaron) (Entered: 08/27/2021)