Mississippi Southern District Court
Judge:Daniel P Jordan, III
Referred: F Keith Ball
Case #: 3:16-cv-00309
Nature of Suit190 Contract - Other Contract
Cause28:1332 Diversity-Contract Dispute
Case Filed:Apr 27, 2016
Terminated:Nov 13, 2017
Last checked: Monday Oct 24, 2016 4:44 AM CDT
Defendant
D. Andre Brown
Defendant
IBC Services, Inc.
Defendant
Pavecon, Ltd.
Represented By
Julie Sneed Herlihy
Wyatt, Tarrant & Combs, Llp - Jackson
contact info
Plaintiff
Bluevine Capital Inc.
Represented By
Lawrence M. Coco, III
Mccraney Coco & Lee, PLLC
contact info
Andrew W. Alderman
Mccraney Coco & Lee, PLLC
contact info


Docket last updated: 2 hours ago
Monday, December 11, 2017
44 44 2 pgs order Order Mon 12/11 5:06 PM
AGREED ORDER AMENDING ORDER OF DISMISSAL: This case is hereby DISMISSED WITH PREJUDICE as to all parties. If any party fails to comply with the terms of this settlement agreed to by all parties, any aggrieved party may reopen the case for enforcement of the settlement agreement. If successful, all additional attorneys' fees and costs from this date shall be awarded such aggrieved party or parties against the party failing to comply with the agreement. The Court specifically retains jurisdiction to enforce the settlement agreement. This settlement will be finally complete upon execution of release documents. Signed by Chief District Judge Daniel P. Jordan III on December 11, 2017.(SP)
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Monday, November 13, 2017
43 43 1 pgs order Order Dismissing Case Mon 11/13 10:59 AM
ORDER DISMISSING CASE - THE PARTIES have agreed to and announced to the Court a settlement of this case. IT IS, THEREFORE, ORDERED that this case is hereby DISMISSED WITH PREJUDICE as to all parties. Signed by Chief District Judge Daniel P. Jordan, III on 11/13/2017 (ND)
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Wednesday, November 08, 2017
minutes Settlement Conference Mon 11/13 9:31 AM
Minute Entry for proceedings held before Magistrate Judge F. Keith Ball: Settlement Conference held on 11/8/2017 in Jackson, MS. Appearances: Lawrence Coco, Jennifer Salvo, Julie Sneed and Daniel Kilman. (JEJ)
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Thursday, October 05, 2017
utility Set/Reset Hearings Thu 10/05 10:18 AM
RESET Hearing: Settlement Conference reset for 11/8/2017 09:00 AM before Magistrate Judge F. Keith Ball. Seven (7) days before the settlement conference, the parties must submit via e-mail to ball_chambers@mssd.uscourts.gov an updated CONFIDENTIAL SETTLEMENT MEMORANDUM. All parties are required to be present at the conference unless excused by the Court. If a party believes the scheduled settlement conference would not be productive and should be cancelled, the party is directed to inform the Court via e-mail of the grounds for their belief at least seven (7) days prior to the conference. (JEJ)
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Tuesday, August 22, 2017
utility Set/Reset Hearings Tue 08/22 9:16 AM
Set Hearing: Settlement Conference set for 11/30/2017 09:00 AM before Magistrate Judge F. Keith Ball. Seven (7) days before the settlement conference, the parties must submit via e-mail to ball_chambers@mssd.uscourts.gov an updated CONFIDENTIAL SETTLEMENT MEMORANDUM. All parties are required to be present at the conference unless excused by the Court. If a party believes the scheduled settlement conference would not be productive and should be cancelled, the party is directed to inform the Court via e-mail of the grounds for their belief at least seven (7) days prior to the conference. (JEJ)
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Friday, August 04, 2017
42 42 order Order on Motion to Continue Fri 08/04 11:12 AM
ORDER granting 40 Motion to Continue; granting 41 Motion to Continue. The pretrial conference scheduled for August 11, 2017 is continued until December 8, 2017, and the trial setting of this matter is continued until this Courts two-week civil litigation term beginning January 2, 2018, all for the purposes of enabling the parties to pursue resolution of this dispute with a settlement conference before Magistrate Keith Ball on November 30, 2017. Signed by District Judge Daniel P. Jordan III on August 4, 2017.(SP)
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utility Set/Reset Hearings Fri 08/04 11:16 AM
Set/Reset Hearings: Pretrial Conference reset for December 8, 2017 at a time to be determined at a later date IN CHAMBERS before District Judge Daniel P. Jordan III; and Jury Trial reset for the Court's two-week civil trial calendar beginning January 2, 2018 at 9:00 AM in Courtroom 5A (Jackson) Jordan before District Judge Daniel P. Jordan III.(SP)
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Friday, July 28, 2017
41 41 motion Continue Fri 07/28 1:17 PM
Joint MOTION to Continue Pre-Trial Conference and Trial by Pavecon, Ltd. (Herlihy, Julie)
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Thursday, July 27, 2017
40 40 motion Continue Thu 07/27 4:02 PM
Joint MOTION to Continue Pre-Trial Conference and Trial by Pavecon, Ltd. (Herlihy, Julie)
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Friday, July 21, 2017
39 39 notice Notice of Calendar Setting Fri 07/21 2:10 PM
NOTICE of Judge Jordan's August 11, 2017 Pretrials and September 5 and 18, 2017 Civil Trial Calendar Setting. (SP)
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utility Set/Reset Hearings Fri 07/21 2:12 PM
Set/Reset Hearings: Pretrial Conference set for August 11, 2017 at 9:00 AM (IN CHAMBERS) before District Judge Daniel P. Jordan III. (SP)
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Tuesday, June 06, 2017
38 38 respm Reply to Response to Motion Tue 06/06 5:38 PM
REPLY to Response to Motion re28 MOTION for Summary Judgment filed by Bluevine Capital Inc.(Coco, Lawrence)
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Att: 1 3 pgs Exhibit J - Correspondence to J. Herlihy,
Att: 2 Exhibit K - DBE Listing for IBC, Inc.
Tuesday, May 30, 2017
37 37 motion Extension of Time to File Response/Reply Tue 05/30 3:48 PM
MOTION for Extension of Time to File Response/Reply as to28 MOTION for Summary Judgment by Bluevine Capital Inc. (Alderman, Andrew)
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36 36 2 pgs misc Affidavit Tue 05/30 3:47 PM
AFFIDAVIT re30 MOTION for Default Judgment as to Defendants IBC Services, Inc. and D. Andre Brown by Bluevine Capital Inc.(Alderman, Andrew)
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Att: 1 Exhibit A - Account Statement
order Order on Motion for Extension of Time to File Response/Reply Tue 05/30 4:29 PM
TEXT ONLY ORDER granting37 Unopposed Motion for Extension of Time to File Response/Reply. Plaintiff's reply shall be filed on or before June 6, 2017. The parties are cautioned that further extensions of the briefing on the pending motions may result in a loss of the current pre-trial and trial settings. No further written order shall issue. Signed by District Judge Daniel P. Jordan III on May 30, 2017. (DI)
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Wednesday, May 17, 2017
order Order on Motion for Extension of Time to File Response/Reply Wed 05/17 8:13 AM
TEXT ONLY ORDER granting35 Unopposed Motion for Extension of Time to File Response/Reply re28 MOTION for Summary Judgment . Plaintiff's reply shall be filed on or before May 30, 2017. No further written order shall issue. Signed by District Judge Daniel P. Jordan III on May 17, 2017. (DI)
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Tuesday, May 16, 2017
35 35 motion Extension of Time to File Response/Reply Tue 05/16 5:44 PM
MOTION for Extension of Time to File Response/Reply as to28 MOTION for Summary Judgment by Bluevine Capital Inc. (Alderman, Andrew)
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Wednesday, May 10, 2017
order Order on Motion for Extension of Time to File Wed 05/10 8:28 AM
TEXT ONLY ORDER granting as unopposed33 Motion for Extension of Time to File. Counsel for Plaintiff advised the Court via email that Plaintiff did not oppose the requested extension. The affidavit of Daniel Kilman [34-15] is deemed timely filed. No further written order shall issue. Signed by District Judge Daniel P. Jordan III on May 10, 2017. (DI)
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Tuesday, May 09, 2017
34 34 misc Amended Document (NOT Motion) Tue 05/09 4:40 PM
AMENDED DOCUMENT by Pavecon, Ltd.. Amendment to32 Response to Motion,,,,, Amended Response of Pavecon, Ltd. to Plaintiff's Motion for Summary Judgment Including Affidavit of Daniel Kilman(Herlihy, Julie)
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Att: 1 Exhibit 1. public records of the Mississippi Secretary of State for IBC Services, Inc. establishing that IBC Services, Inc. is a Mississippi corporation that has been dissolved,
Att: 2 Exhibit 2. Invoice Purchase and Security Agreement,
Att: 3 Exhibit 3. Mendrops email to Pavecon,
Att: 4 Exhibit 4. Mendrops October 21, 2015 email to Pavecon,
Att: 5 Exhibit 5. Mendrops emails to Pavecon dated the same day as the alleged notice, October 19, 2015,
Att: 6 Exhibit 6. Mendrops email dated October 27, 2015,
Att: 7 Exhibit 7. Mendrops October 30, 2015,
Att: 8 Exhibit 8. Complaint filed with the Mississippi State Board of Contractors,
Att: 9 Exhibit 9. Pavecons response to IBC, Inc.s Complaint before the Mississippi State Board of Contractors,
Att: 10 Exhibit 10. State of Mississippis Unified Certification Certificates establishing that IBC, Inc., and its successor-in-interest, Concrete Constructors Southeast, Inc., are DBEs,
Att: 11 Exhibit 11. Citys award of the contract to Pavecon was contingent upon Pavecon satisfying Mississippis DBE Program requirements,
Att: 12 Exhibit 12. Form OCR-481 signed by Pavecon and IBC, Inc.,
Att: 13 Exhibit 13. signature page,
Att: 14 Exhibit 14. copies of public records of the Mississippi Secretary of State establishing that IBC, Inc. now Concrete Constructors Southeast, Inc. is a Mississippi corporation separate from IBC Services,
Att: 15 Exhibit 15. Affidavit of Daniel Kilman,
Att: 16 Exhibit 16. invoice relied upon by Bluevine arose from IBC, Inc.s unit price subcontract on the Batesville project
Monday, May 08, 2017
33 33 motion Extension of Time to File Document Mon 05/08 6:01 PM
MOTION for Extension of Time to File Affidavit by Pavecon, Ltd. (Herlihy, Julie)
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32 32 respm Response to Motion Mon 05/08 5:59 PM
RESPONSE to Motion re28 MOTION for Summary Judgment filed by Pavecon, Ltd.(Herlihy, Julie)
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Att: 1 Exhibit 1. A true and correct copy of the public records of the Mississippi Secretary of State for IBC Services, Inc. establishing that IBC Services, Inc. is a Mississippi corporation that has been dissolved,
Att: 2 Exhibit 2. Invoice Purchase and Security Agreement,
Att: 3 Exhibit 3. Mendrops email to Pavecon,
Att: 4 Exhibit 4. Mendrops October 21, 2015 email to Pavecon,
Att: 5 Exhibit 5. Mendrops emails to Pavecon dated the same day as the alleged notice, October 19, 2015,
Att: 6 Exhibit 6. Mendrops email dated October 27, 2015,
Att: 7 Exhibit 7. Mendrops October 30, 2015 letter,
Att: 8 Exhibit 8. Complaint filed with the Mississippi State Board of Contractors,
Att: 9 Exhibit 9. Pavecons response to IBC, Inc.s Complaint before the Mississippi State Board of Contractors,
Att: 10 Exhibit 10. State of Mississippis Unified Certification Certificates establishing that IBC, Inc., and its successor-in-interest, Concrete Constructors Southeast, Inc., are DBEs,
Att: 11 Exhibit 11. Citys award of the contract to Pavecon was contingent upon Pavecon satisfying Mississippis DBE Program requirements,
Att: 12 Exhibit 12. Form OCR-481 signed by Pavecon and IBC, Inc.,
Att: 13 Exhibit 13. full content of the signature page
Tuesday, May 02, 2017
utility Remark Tue 05/02 9:47 AM
REMARK:: The Clerk is unable to enter default judgment as requested [Doc # 30] in the absence of the affidavit required by Rule 55(b)(1) of the Federal Rules of Civil Procedure. Counsel is requested to file the same. (ASJ)
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Wednesday, April 26, 2017
31 31 respm Rebuttal Wed 04/26 5:34 PM
Rebuttal re21 MOTION for Summary Judgment filed by Pavecon, Ltd.(Herlihy, Julie)
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Att: 1 Exhibit A. Pavecon's July 6, 2016, letter to counsel for Bluevine,
Att: 2 Exhibit B. Bluevine's July 12, 2016, letter to counsel for Pavecon
Monday, April 24, 2017
30 30 motion Default Judgment Mon 04/24 5:33 PM
MOTION for Default Judgment as to Defendants IBC Services, Inc. and D. Andre Brown by Bluevine Capital Inc.(Coco, Lawrence)
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Att: 1 Exhibit A - Account Statement
29 29 respm Memorandum in Support of Motion Mon 04/24 4:55 PM
MEMORANDUM in Support re28 MOTION for Summary Judgment filed by Bluevine Capital Inc. (Coco, Lawrence)
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28 28 motion Summary Judgment Mon 04/24 4:44 PM
MOTION for Summary Judgment by Bluevine Capital Inc.(Coco, Lawrence)
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Att: 1 Exhibit A - Master Service Agreement,
Att: 2 Exhibit B - Affidavit of Hanono,
Att: 3 Exhibit C - Invoice Purchase Agreement,
Att: 4 Exhibit D - Assignment Notice,
Att: 5 Exhibit E - Email Correspondence,
Att: 6 Exhibit F - Demand Letter,
Att: 7 Exhibit G - Statement of Account,
Att: 8 Exhibit I - IBC Invoice
Wednesday, April 19, 2017
27 27 respm Response in Opposition to Motion Wed 04/19 4:30 PM
RESPONSE in Opposition re21 MOTION for Summary Judgment filed by Bluevine Capital Inc.(Coco, Lawrence)
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Att: 1 Exhibit A - Master Service Agreement,
Att: 2 Exhibit B - Affidavit of Hanono,
Att: 3 Exhibit C - Invoice Purchase Agreement,
Att: 4 Exhibit D - Assignment Notice,
Att: 5 Exhibit E - Email Correspondence,
Att: 6 Exhibit F - Demand Letter,
Att: 7 Exhibit G - Statement of Account,
Att: 8 Exhibit H - Acknowledgement of Assignment,
Att: 9 Exhibit I - IBC Invoice
Tuesday, April 18, 2017
26 26 order Order on Motion to Extend Deadline Tue 04/18 1:17 PM
ORDER granting20 Motion to Extend Deadline. Signed by Magistrate Judge F. Keith Ball on 4/18/2017. (JRB)
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utility Set/Reset Deadlines Tue 04/18 1:18 PM
Set/Reset Deadlines: Per the Court's order26 , Motions due by 4/24/2017. (JRB)
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Monday, April 17, 2017
25 25 discov Notice of Service of Response to Request for Production Mon 04/17 2:45 PM
NOTICE of Service of Supplemental Response to Request for Production by Bluevine Capital Inc. (Alderman, Andrew)
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24 24 discov Notice of Service of Response to Interrogatories Mon 04/17 2:45 PM
NOTICE of Service of Supplemental Response to Interrogatories by Bluevine Capital Inc. (Alderman, Andrew)
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Tuesday, April 11, 2017
order Order Tue 04/11 9:02 AM
TEXT-ONLY ORDER cancelling settlement conference set for April 12, 2017. No further written order shall issue from the Court. Signed by Magistrate Judge F. Keith Ball on 4/11/2017. (JEJ)
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Wednesday, April 05, 2017
23 23 respm Response to Motion Wed 04/05 5:26 PM
RESPONSE to Motion re20 MOTION to Extend Dispositive Motion Deadline (Objection) filed by Pavecon, Ltd. (Herlihy, Julie)
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22 22 respm Memorandum in Support of Motion Wed 04/05 4:49 PM
MEMORANDUM in Support re21 MOTION for Summary Judgment filed by Pavecon, Ltd. (Herlihy, Julie)
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21 21 motion Summary Judgment Wed 04/05 4:47 PM
MOTION for Summary Judgment by Pavecon, Ltd.(Herlihy, Julie)
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Att: 1 Exhibit A - MS Secretary of State Documents,
Att: 2 Exhibit B - MS Secretary of State Documents,
Att: 3 Exhibit C - re: Certificate of Responsibility,
Att: 4 Exhibit D - Certification,
Att: 5 Exhibit E - Excerpts from Contract,
Att: 6 Exhibit F - OCR 481,
Att: 7 Exhibit G - Master Subcontract Agreement,
Att: 8 Exhibit H - Request for Permission to Subcontract,
Att: 9 Exhibit I - Email From Mendrop, Batesville Issues,
Att: 10 Exhibit J - Mendrop Email to Pavecon,
Att: 11 Exhibit K - Mendrop Email to Pavecon re Crew,
Att: 12 Exhibit L - Mendrop Email,
Att: 13 Exhibit M - Letter to Pavecon from Mendrop,
Att: 14 Exhibit N - Affidavit of Daniel Kilman
20 20 motion Extend Deadline Wed 04/05 4:38 PM
MOTION to Extend Dispositive Motion Deadline by Bluevine Capital Inc. (Coco, Lawrence)
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Tuesday, January 17, 2017
19 19 discov Notice of Service of Request for Production Tue 01/17 4:10 PM
NOTICE of Service of Request for Production by Pavecon, Ltd. (Herlihy, Julie)
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18 18 discov Notice of Service of Interrogatories Tue 01/17 4:08 PM
NOTICE of Service of Interrogatories by Pavecon, Ltd. (Herlihy, Julie)
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17 17 notice Notice (Other) - DO NOT USE FOR APPEALS OR DISCOVERY Tue 01/17 4:06 PM
NOTICE of Change of Firm by Pavecon, Ltd. (Herlihy, Julie)
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Friday, October 21, 2016
16 16 respm Response to Order Fri 10/21 2:34 PM
Response to Order re15 ORDER TO SHOW CAUSE: For the reasons set out in the Order, Pavecon shall file a response to this Order within ten days of the entry of this order, indicating the citizenship of each of its partners. If the partners include other partnerships or LLCs, then the citizenship of those members must be fully traced and disclosed. Signed by District Judge Daniel P. Jordan III on October 12, 2016.(SP) filed by Pavecon, Ltd. (Herlihy, Julie)
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Wednesday, October 12, 2016
15 15 order Order to Show Cause Wed 10/12 4:41 PM
ORDER TO SHOW CAUSE: For the reasons set out in the Order, Pavecon shall file a response to this Order within ten days of the entry of this order, indicating the citizenship of each of its partners. If the partners include other partnerships or LLCs, then the citizenship of those members must be fully traced and disclosed. Signed by District Judge Daniel P. Jordan III on October 12, 2016.(SP)
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Thursday, September 15, 2016
14 14 discov Notice of Service of Disclosure Thu 09/15 4:59 PM
NOTICE of Service of Initial Disclosure by Bluevine Capital Inc. (Coco, Lawrence)
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Monday, September 12, 2016
13 13 order Case Management Order Mon 09/12 10:42 AM
CASE MANAGEMENT ORDER. Disclosure due by 9/15/2016; Motions for Amended Pleadings due by 10/3/2016; Motions for Joinder of Parties due by 10/3/2016; Designate Experts Plaintiff Deadline due by 12/23/2016; Designate Experts for Defendant Deadline due by 1/23/2017; Discovery due by 3/22/2017; Motions due by 4/5/2017; Settlement Conference set for 4/12/2017 09:00 AM before Magistrate Judge F. Keith Ball; Pretrial Conference set for 8/11/2017, time to be determined, in Courtroom 5A (Jackson) Jordan before District Judge Daniel P. Jordan III; Jury Trial set for a two-week term of court commencing 9/5/2017 09:00 AM in Courtroom 5A (Jackson) Jordan before District Judge Daniel P. Jordan III. Signed by Magistrate Judge F. Keith Ball on 9/12/2016. (JEJ)
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Tuesday, September 06, 2016
12 12 discov Notice of Service of Disclosure Tue 09/06 4:24 PM
NOTICE of Service of Pre-Discovery Disclosure of Core Information Disclosure by Pavecon, Ltd. (Herlihy, Julie)
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Thursday, September 01, 2016
minutes Telephonic Case Management Conference Mon 09/12 9:27 AM
Minute Entry for proceedings held before Magistrate Judge F. Keith Ball: Telephonic Case Management Conference held on 9/1/2016 in Jackson, MS. Appearances: Lawrence Coco, Andrew Alderman and Julie Herlihy. (JEJ)
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Tuesday, August 30, 2016
utility Set/Reset Hearings Tue 08/30 10:11 PM
Set/Reset Hearings (TIME CHANGE ONLY): Telephonic Case Management Conference reset for 9/1/2016 10:00 AM before Magistrate Judge F. Keith Ball. No later than seven (7) days prior to the TCMC, a confidential memorandum AND a proposed Case Management Order shall be submitted via e-mail to ball_chambers@mssd.uscourts.gov. Counsel for Plaintiff shall set up the conference and contact the Court at 601-608-4460. (JRB)
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Thursday, August 25, 2016
11 11 1 pgs order Clerks Entry of Default Thu 08/25 2:13 PM
Clerk's ENTRY OF DEFAULT as to D. Andre Brown, IBC Services, Inc. (RRL)
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10 10 motion Entry of Default Thu 08/25 1:52 PM
MOTION for Entry of Default Against IBC Services, Inc. and D. Andre Brown by Bluevine Capital Inc. (Coco, Lawrence)
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Tuesday, August 23, 2016
9 9 service Summons Returned Executed Tue 08/23 3:09 PM
SUMMONS Returned Executed by Bluevine Capital Inc. D. Andre Brown served on 7/19/2016, answer due 8/9/2016. (Alderman, Andrew)
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8 8 service Summons Returned Executed Tue 08/23 3:08 PM
SUMMONS Returned Executed by Bluevine Capital Inc. IBC Services, Inc. served on 7/19/2016, answer due 8/9/2016. (Alderman, Andrew)
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Tuesday, July 19, 2016
utility Set/Reset Hearings Tue 07/19 2:43 PM
RESET Hearing: Telephonic Case Management Conference reset for 9/1/2016 03:00 PM before Magistrate Judge F. Keith Ball. No later than seven (7) days prior to the TCMC, a confidential memorandum AND a proposed Case Management Order shall be submitted via e-mail to ball_chambers@mssd.uscourts.gov. Counsel for Plaintiff shall set up the conference and contact the Court at 601-608-4460. (JEJ)
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Thursday, June 16, 2016
7 7 notice Rule 16(a) Initial Order Thu 06/16 3:01 PM
Rule 16(a) Initial Order Telephonic Case Management Conference set for 7/20/2016 02:00 PM before Magistrate Judge F. Keith Ball. No later than seven (7) days prior to the TCMC, a confidential memorandum AND a proposed Case Management Order shall be submitted via e-mail to ball_chambers@mssd.uscourts.gov. Counsel for Plaintiff shall set up the conference and contact the Court at 601-608-4460. (JEJ)
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Monday, June 06, 2016
6 6 8 pgs answer Answer to Complaint Mon 06/06 11:29 AM
ANSWER to1 Complaint, by Pavecon, Ltd..(Herlihy, Julie)
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Thursday, May 19, 2016
order Order on Motion for Extension of Time to Answer Thu 05/19 11:38 AM
TEXT-ONLY ORDER granting5 Motion for Extension of Time to Answer. Pavecon, Ltd. answer due 6/6/2016. NO FURTHER WIRTTEN ORDER SHALL ISSUE. Signed by Magistrate Judge F. Keith Ball on 5/19/2016. (JRB)
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Wednesday, May 18, 2016
5 5 motion Extension of Time to File Answer Wed 05/18 2:16 PM
MOTION for Extension of Time to File Answer by Pavecon, Ltd. (Herlihy, Julie)
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Tuesday, May 17, 2016
4 4 notice Notice of Appearance Tue 05/17 11:31 AM
NOTICE of Appearance by Julie Sneed Herlihy on behalf of Pavecon, Ltd. (Herlihy, Julie)
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Monday, May 02, 2016
3 3 service Summons Returned Executed Mon 05/02 3:45 PM
SUMMONS Returned Executed by Bluevine Capital Inc. Pavecon, Ltd. served on 5/2/2016, answer due 5/23/2016. (Alderman, Andrew)
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Wednesday, April 27, 2016
2 2 service Summons Issued Wed 04/27 1:36 PM
Summons Issued as to D. Andre Brown, IBC Services, Inc., Pavecon, Ltd. (RRL)
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1 1 cmp Complaint Wed 04/27 1:26 PM
COMPLAINT against D. Andre Brown, IBC Services, Inc., Pavecon, Ltd. ( Filing fee $ 400 receipt number 34643039004), filed by Bluevine Capital Inc.(RRL)
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Att: 1 Exhibit A-Invoice Purchase and Security Agreement,
Att: 2 Exhibit B-Unconditional Individual Guaranty,
Att: 3 Exhibit C-Letter from E. Castans to S. Anderson,
Att: 4 Exhibit D-Letter from S. Hefetz-Carmeli to S. Anderson,
Att: 5 Exhibit E-Letter from S. Hefetz-Carmeli to D. Brown,
Att: 6 Civil Cover Sheet