Case: Zou v. Grasso

Zou v. Ono

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)

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)

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

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)

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

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)

Appear*

Protective Order

Response to Motion

Withdraw Motion