California Central District Court
Judge:Michael W Fitzgerald
Referred: Jacqueline Chooljian
Case #: 2:23-cv-02037
Nature of Suit791 Labor - Employee Retirement Income Security Act
Cause28:1441 Notice of Removal - Labor/Mgmnt. Relations
Case Filed:Mar 17, 2023
Case in other court:Los Angeles County Superior Court, 23STCV03390
Last checked: Saturday Sep 16, 2023 9:55 AM PDT
Defendant
Apple, Inc.
Represented By
Kathleen Cahill Slaught
Seyfarth Shaw LLP
contact info
Amanda L. Genovese
Seyfarth Shaw LLP
contact info
Ryan Robert Tikker
Seyfarth Shaw LLP
contact info
Defendant
Does
Defendant
United Healthcare Insurance Company
Represented By
Kathleen Cahill Slaught
Seyfarth Shaw LLP
contact info
Plaintiff
Mehdi Eskandarloo
Represented By
Jonathan Aaron Stieglitz
Law Offices Of Jonathan Stieglitz
contact info
TERMINATED PARTIES
Defendant
United Healthcare Services, Inc.
Terminated: 08/27/2023
Represented By
Kathleen Cahill Slaught
Seyfarth Shaw LLP
contact info
Amanda L. Genovese
Seyfarth Shaw LLP
contact info
Ryan Robert Tikker
Seyfarth Shaw LLP
contact info


Docket last updated: 04/24/2024 11:59 PM PDT
Friday, December 08, 2023
43 43 adr Notice of Assignment of Panel Mediator (ADR-11) - optional html form Fri 12/08 7:55 AM
NOTICE OF ASSIGNMENT of Panel Mediator. Mediator (ADR Panel) Laurence S Zakson has been assigned to serve as Panel Mediator. (lst)
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Monday, October 16, 2023
42 42 order Pretrial-Trial Scheduling Order - form only Tue 10/17 12:53 PM
ORDER RE COURT TRIAL by Judge Michael W. Fitzgerald. Last Day to Add Parties/Amend Pleadings 2/2/2024. Last Day to Hear Motions 6/3/2024. Final Pretrial Conference and Hearing on Motions in Limine set for 8/5/2024 at 11:00 AM. Trial Date (Est. 1 to 2 Days) set for 8/27/2024 at 8:30 AM. SEE ORDER FOR DETAILS. (iv)
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41 41 order Order/Referral to ADR (No 2) (Mediation Panel) (ADR-12) Mon 10/16 5:15 PM
ORDER/REFERRAL to ADR Procedure No 2 by Judge Michael W. Fitzgerald. Case ordered to Court Mediation Panel for mediation. ADR Proceeding to be held no later than 6/14/2024. (iv)
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40 40 textonly Text Only Scheduling Notice Mon 10/16 11:30 AM
SCHEDULING NOTICE and ORDER by Judge Michael W. Fitzgerald. On its own motion, the Court VACATES the Scheduling Conference set for 10/23/2023 at 11:00 a.m. No appearances shall be made. The Court will review the parties' Joint Rule 26(f) Report and issue pretrial and trial dates by separate order. IT IS SO ORDERED. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (smom)
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Friday, October 06, 2023
39 39 misc Joint Report Rule 26(f) Discovery Plan Fri 10/06 4:47 PM
JOINT REPORT Rule 26(f) Discovery Plan ; estimated length of trial 1, filed by Defendants Apple, Inc., United Healthcare Insurance Company.. (Slaught, Kathleen)
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Tuesday, September 19, 2023
38 38 order Initial Order Setting R26 Scheduling Conference - form only Tue 09/19 10:21 AM
ORDER SETTING SCHEDULING CONFERENCE by Judge Michael W. Fitzgerald. Scheduling Conference set for 10/23/2023 at 11:00 AM before Judge Michael W. Fitzgerald. (smom)
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Monday, September 11, 2023
37 37 answer Answer to Complaint (Discovery) Mon 09/11 11:48 AM
ANSWER to Amended Complaint/Petition35 filed by Defendants Apple, Inc., United Healthcare Insurance Company.(Attorney Kathleen Cahill Slaught added to party United Healthcare Insurance Company(pty:dft))(Slaught, Kathleen)
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Sunday, August 27, 2023
36 36 attyseal Sealed Document Sun 08/27 11:04 AM
SEALED DOCUMENT re Amended Complaint/Petition35 , Order on Motion for Leave to File Document Under Seal,34 filed by Plaintiff Mehdi Eskandarloo.(Stieglitz, Jonathan)
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35 35 othcmp Amended Complaint/Petition Sun 08/27 11:02 AM
Second AMENDED COMPLAINT against Defendants Apple, Inc., United Healthcare Services, Inc. amending Amended Complaint/Petition26 , filed by plaintiff Mehdi Eskandarloo(Stieglitz, Jonathan)
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Thursday, June 22, 2023
34 34 order Leave to File Document Under Seal Thu 06/22 9:23 AM
MINUTES (IN CHAMBERS) ORDER GRANTING PLAINTIFF'S APPLICATION TO FILE UNDER SEAL AND JOINT STIPULATION FOR LEAVE TO FILE SECOND AMENDED COMPLAINT31 ,32 by Judge Michael W. Fitzgerald. The Application is GRANTED. Further, the Joint Stipulation to allow Plaintiff leave to file the SAC is GRANTED. Per the Joint Stipulation, Defendants shall file a response to the SAC within 14 days of the filing of the SAC. (iv)
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Wednesday, June 21, 2023
33 33 notice Deficiency in Electronically Filed Documents (G-112A) - optional html form Wed 06/21 8:03 AM
NOTICE TO FILER OF DEFICIENCIES in Electronically Filed Document RE: APPLICATION to file under seal31 . The following error(s) was/were found: Application to file under seal is lacking accompanied documents. Refer to L.R. 79-5.2.2 for proper filing instructions. In response to this notice, the Court may: (1) order an amended or correct document to be filed; (2) order the document stricken; or (3) take other action as the Court deems appropriate. You need not take any action in response to this notice unless and until the Court directs you to do so. (iv)
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Tuesday, June 20, 2023
32 32 stip Leave Tue 06/20 5:24 PM
Joint STIPULATION for Leave to Amend Complaint filed by plaintiff Mehdi Eskandarloo.(Stieglitz, Jonathan)
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Att: 1 Exhibit,
Att: 2 Proposed Order
31 31 motion Leave to File Document Under Seal Tue 06/20 5:14 PM
APPLICATION to file document Portions of Second Amended Complaint under seal filed by Plaintiff Mehdi Eskandarloo.(Stieglitz, Jonathan)
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Att: 1 Declaration,
Att: 2 Proposed Order,
Att: 3 Redacted Document REDACTED SAC PROPOSED TO BE FILED
Friday, June 16, 2023
30 30 misc Response Fri 06/16 5:59 PM
RESPONSE filed by Defendants Apple, Inc., United Healthcare Services, Inc.to Text Only Scheduling Notice,, 27 (Slaught, Kathleen)
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Monday, June 05, 2023
29 29 order Protective Order Tue 06/06 10:01 AM
PROTECTIVE ORDER by Magistrate Judge Jacqueline Chooljian re Stipulation for Protective Order28 . (see document for details) (hr)
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28 28 stip Protective Order Mon 06/05 9:59 AM
STIPULATION for Protective Order filed by Defendants Apple, Inc., United Healthcare Services, Inc..(Tikker, Ryan)
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Att: 1 Proposed Order re Stipulated Protective Order
27 27 textonly Text Only Scheduling Notice Mon 06/05 9:56 AM
SCHEDULING NOTICE and ORDER by Judge Michael W. Fitzgerald. In light of Plaintiff's First Amended Complaint26 ("FAC") filed 6/2/2023, the Court DENIES as moot Defendants' Application to File Documents Under Seal22 and Motion to Dismiss Plaintiff's Complaint24 ("MTD"), and VACATES the 6/26/2023 hearing on the MTD. The Court will correct the docket entry for the FAC to reflect that a First, not Second, Amended Complaint has been filed. IT IS SO ORDERED. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (smom)
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Sunday, June 04, 2023
26 26 othcmp Amended Complaint/Petition Sun 06/04 10:48 PM
Second AMENDED COMPLAINT against Defendants All Defendants amending Complaint - (Discovery),, filed by plaintiff Mehdi Eskandarloo(Stieglitz, Jonathan)
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Friday, May 12, 2023
25 25 misc For Judicial Notice Fri 05/12 8:28 PM
REQUEST FOR JUDICIAL NOTICE re APPLICATION to file document pursuant to Local Rule 79-5 under seal22 , NOTICE OF MOTION AND MOTION to Dismiss Plaintiff's Complaint 24 filed by Defendants Apple, Inc., United Healthcare Services, Inc..(Slaught, Kathleen)
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Att: 1 Proposed Warrant
24 24 motion Dismiss (cause or other) Fri 05/12 8:26 PM
NOTICE OF MOTION AND MOTION to Dismiss Plaintiff's Complaint filed by Defendants Apple, Inc., United Healthcare Services, Inc.. Motion set for hearing on 6/26/2023 at 10:00 AM before Judge Michael W. Fitzgerald. (Slaught, Kathleen)
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Att: 1 Declaration in support,
Att: 2 Exhibit A to Declaration in support,
Att: 3 Proposed Order
23 23 attyseal Sealed Declaration in Support Fri 05/12 8:20 PM
SEALED DECLARATION IN SUPPORT OF APPLICATION to file document pursuant to Local Rule 79-5 under seal22 filed by Defendants Apple, Inc., United Healthcare Services, Inc..(Slaught, Kathleen)
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Att: 1 Unredacted Document,
Att: 2 Unredacted Document,
Att: 3 Redacted Document,
Att: 4 Redacted Document
22 22 motion Leave to File Document Under Seal Fri 05/12 7:41 PM
APPLICATION to file document pursuant to Local Rule 79-5 under seal filed by Defendants Apple, Inc., United Healthcare Services, Inc..(Slaught, Kathleen)
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Att: 1 Proposed Order,
Att: 2 Declaration of NCanova in support,
Att: 3 Redacted Document Motion to Dismiss,
Att: 4 Redacted Document Exhibit A to Declaration in support of Motion to Dismiss
Wednesday, April 05, 2023
21 21 order Extending Answer Due Deadline Wed 04/05 1:18 PM
ORDER GRANTING STIPULATION AND REQUEST TO EXTEND TIME TO RESPOND TO COMPLAINT DUE TO ONGOING CONFERRAL20 by Judge Michael W. Fitzgerald. The deadline by which Defendants have to answer or otherwise respond to the Complaint shall be extended to May 12, 2023. (iv)
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Tuesday, April 04, 2023
20 20 stip Extending Time to Answer (More than 30 days) Tue 04/04 5:58 PM
STIPULATION for Extension of Time to File Answer to May 12, 2023 filed by Defendants Apple, Inc., United Healthcare Services, Inc..(Slaught, Kathleen)
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Att: 1 Proposed Order Granting Stipulation and Request to Extend Time to Respond to Complaint
19 19 order Appear Pro Hac Vice Tue 04/04 4:44 PM
ORDER by Judge Michael W. Fitzgerald: Granting Application of Non-Resident Attorney Amanda Genovese to Appear Pro Hac Vice on behalf of Defendant Apple, Inc and United HealthCare Services, Inc., designating Ryan Tikker as local counsel17 . (iv)
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18 18 notice Notice of Deficiency in Electronically filed Pro Hac Vice Application (G-112C) - optional html form Tue 04/04 2:31 PM
NOTICE of Deficiency in Electronically Filed Pro Hac Vice Application RE: APPLICATION of Non-Resident Attorney Amanda L. Genovese to Appear Pro Hac Vice on behalf of Defendants Apple, Inc., United Healthcare Services, Inc. (Pro Hac Vice Fee - $500.00 Previously Paid on 3/20/2023, Receipt No. 34989373)17 . The following error(s) was/were found: Proposed Order has not been flattened and is causing a corruption with the filing. (lt)
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Friday, March 31, 2023
17 17 motion Appear Pro Hac Vice (G-64) Fri 03/31 12:10 PM
APPLICATION of Non-Resident Attorney Amanda L. Genovese to Appear Pro Hac Vice on behalf of Defendants Apple, Inc., United Healthcare Services, Inc. (Pro Hac Vice Fee - $500.00 Previously Paid on 3/20/2023, Receipt No. 34989373) filed by Defendants Apple, Inc., United Healthcare Services, Inc.. (Tikker, Ryan)
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Att: 1 Proposed Order
Friday, March 24, 2023
16 16 order Response By Court to Notice of Deficiencies (G-112B) - optional html form Fri 03/24 2:42 PM
RESPONSE BY THE COURT TO NOTICE TO FILER OF DEFICIENCIES IN FILED DOCUMENT RE: Notice of Deficiency in Electronically filed Pro Hac Vice Application (G-112C) -15 by Judge Michael W. Fitzgerald. The document is stricken. Filer has also not complied with Local Rule 5-4.4 which requires that a word-processing version of the proposed Order be emailed to chambers. (smom)
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Thursday, March 23, 2023
15 15 notice Notice of Deficiency in Electronically filed Pro Hac Vice Application (G-112C) - optional html form Thu 03/23 6:04 PM
NOTICE of Deficiency in Electronically Filed Pro Hac Vice Application RE: APPLICATION of Non-Resident Attorney Amanda L. Genovese to Appear Pro Hac Vice on behalf of Defendants Apple, Inc., United Healthcare Services, Inc. (Pro Hac Vice Fee - $500 Previously Paid on 3/20/2023, Receipt No. 34989373)14 . The following error(s) was/were found: Local Rule 83-2.1.3.3(a) Application not complete: state and/or federal courts to which the applicant has been admitted are not listed. Other error(s) with document(s): Applicant failed to list state bars where they are admitted. Only listed appellate and district courts. See Instructions for Applicants (1)(G-64). (lt)
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Wednesday, March 22, 2023
14 14 motion Appear Pro Hac Vice (G-64) Wed 03/22 4:37 PM
APPLICATION of Non-Resident Attorney Amanda L. Genovese to Appear Pro Hac Vice on behalf of Defendants Apple, Inc., United Healthcare Services, Inc. (Pro Hac Vice Fee - $500 Previously Paid on 3/20/2023, Receipt No. 34989373) filed by Defendants Apple, Inc., United Healthcare Services, Inc.. (Tikker, Ryan)
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Att: 1 Proposed Order
Tuesday, March 21, 2023
13 13 order Response By Court to Notice of Deficiencies (G-112B) - optional html form Tue 03/21 4:44 PM
RESPONSE BY THE COURT TO NOTICE TO FILER OF DEFICIENCIES IN FILED DOCUMENT RE: Notice of Deficiency in Electronically filed Pro Hac Vice Application (G-112C) -10 by Judge Michael W. Fitzgerald. The document is stricken. (smom)
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12 12 cs_rasgn Reassign Case - Self -Recusal --pursuant GO 21-01 (CV-52) Tue 03/21 4:28 PM
ORDER TO REASSIGN CASE due to self-recusal pursuant to General Order 21-01 by Judge Christina A. Snyder. Case transferred from Judge Christina A. Snyder to the calendar of Judge Michael W. Fitzgerald for all further proceedings. Case number now reads as 2:23-cv-02037 MWF(JCx). (rn)
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11 11 stip Extending Time to Answer (30 days or less) Tue 03/21 3:33 PM
STIPULATION Extending Time to Answer the complaint as to United Healthcare Services, Inc. answer now due 4/14/2023; Apple, Inc. answer now due 4/14/2023, filed by Defendants United Healthcare Services, Inc.; Apple, Inc..(Slaught, Kathleen)
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10 10 notice Notice of Deficiency in Electronically filed Pro Hac Vice Application (G-112C) - optional html form Tue 03/21 12:30 PM
NOTICE of Deficiency in Electronically Filed Pro Hac Vice Application RE: APPLICATION of Non-Resident Attorney Amanda L. Genovese to Appear Pro Hac Vice on behalf of Defendants Apple, Inc., United Healthcare Services, Inc. (Pro Hac Vice Fee - $500 Fee Paid, Receipt No. ACACDC-34989373)9 . The following error(s) was/were found: Local Rule 83-2.1.3.4 Local counsel does not maintain an office within the District. Local Rule 5-4.3.4 Application not hand-signed, as to local counsel. (sbou)
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Monday, March 20, 2023
9 9 motion Appear Pro Hac Vice (G-64) Mon 03/20 5:01 PM
APPLICATION of Non-Resident Attorney Amanda L. Genovese to Appear Pro Hac Vice on behalf of Defendants Apple, Inc., United Healthcare Services, Inc. (Pro Hac Vice Fee - $500 Fee Paid, Receipt No. ACACDC-34989373) filed by Defendants Apple, Inc., United Healthcare Services, Inc.. (Slaught, Kathleen)
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Att: 1 Proposed Order
8 8 attorney Pro Hac Vice Application Due (G-109) - optional html form Mon 03/20 11:00 AM
NOTICE OF PRO HAC VICE APPLICATION DUE for Non-Resident Attorney Amanda L. Genovese. A document recently filed in this case lists you as an out-of-state attorney of record. However, the Court has not been able to locate any record that you are admitted to the Bar of this Court, and you have not filed an application to appear Pro Hac Vice in this case. Accordingly, within 5 business days of the date of this notice, you must either (1) have your local counsel file an application to appear Pro Hac Vice (Form G-64) and pay the applicable fee, or (2) complete the next section of this form and return it to the court at cacd_attyadm@cacd.uscourts.gov. You have been removed as counsel of record from the docket in this case, and you will not be added back to the docket until your Pro Hac Vice status has been resolved. (sh)
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7 7 notice Notice to Counsel Re: Consent to Proceed Before a US Magistrate Judge - optional html form Mon 03/20 10:59 AM
Notice to Counsel Re Consent to Proceed Before a United States Magistrate Judge. (sh)
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6 6 adr Notice to Parties of Court-Directed ADR Program (ADR-8) - optional html form Mon 03/20 10:58 AM
NOTICE TO PARTIES OF COURT-DIRECTED ADR PROGRAM filed. (sh)
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5 5 notice Notice of Assignment to United States Judges (CV-18) - optional html form Mon 03/20 10:58 AM
NOTICE OF ASSIGNMENT to District Judge Christina A. Snyder and Magistrate Judge Jacqueline Chooljian. (sh)
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Friday, March 17, 2023
4 4 notice Certificate/Notice of Interested Parties Fri 03/17 5:04 PM
CERTIFICATE of Interested Parties filed by Defendants Apple, Inc., United Healthcare Services, Inc., identifying Plaintiff Mehdi Eskandarloo, Advanced Weight Loss Surgical Association, Minimally Invasive Surgical Association, Defendant Apple Inc., Defendant United Healthcare Services, Inc.. (Slaught, Kathleen)
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3 3 misc Civil Cover Sheet (CV-71) Fri 03/17 5:02 PM
CIVIL COVER SHEET filed by Defendants Apple, Inc., United Healthcare Services, Inc.. (Slaught, Kathleen)
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2 2 service Proof of Service (subsequent documents) Fri 03/17 4:58 PM
PROOF OF SERVICE filed by Defendants Apple, Inc., United Healthcare Services, Inc., re Notice of Removal (Attorney Civil Case Opening),,1 served on March 17, 2023. (Slaught, Kathleen)
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1 1 notice Notice of Removal (Attorney Civil Case Opening) Fri 03/17 4:56 PM
NOTICE OF REMOVAL from Los Angeles Superior Court, case number 23STCV03390 Receipt No: ACACDC-34979764 - Fee: $402, filed by Defendants United Healthcare Services, Inc., Apple, Inc.. (Attorney Kathleen Cahill Slaught added to party Apple, Inc.(pty:dft), Attorney Kathleen Cahill Slaught added to party United Healthcare Services, Inc.(pty:dft))(Slaught, Kathleen)
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Att: 1 9 pgs Exhibit A,
Att: 2 Exhibit B,
Att: 3 Declaration Declaration of Jane Stalinski,
Att: 4 Exhibit A to Declaration of Jane Stalinski
cmp Complaint - (Discovery) Mon 03/20 10:52 AM
CONFORMED E-FILED COPY OF SUMMONS AND COMPLAINT against Defendants Apple, Inc., Does, United Healthcare Services, Inc.. Jury Demanded. filed by Plaintiff Mehdi Eskandarloo.[FILED IN STATE COURT 02/16/2023 SUBMITTED AS ATTACHMENT NO. 1 EXHIBIT A TO THE NOTICE OF REMOVAL1 ] (sh)
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