Primacy, LLC v. Cyr et al
| Connecticut District Court | |
| Judge: | Jeffrey A Meyer |
| Referred: | Thomas O Farrish |
| Case #: | 3:24-cv-00717 |
| Nature of Suit | 880 Civil Rights - Defend Trade Secrets Act of 2016 (DTSA) |
| Cause | 18:1836(a) Injunction against Misappropriation of Trade Secrets |
| Case Filed: | Apr 17, 2024 |
| Last checked: Wednesday Apr 17, 2024 12:10 PM EDT |
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Defendant
Matthew Cyr
2412 Parsonage Woods Lane
Mount Pleasant, SC 29466 |
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Defendant
Unlock Health, Inc.
209 10th Avenue South
Nashville, TN 37203 |
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Plaintiff
Primacy, LLC
1577 New Britain Avenue
Farmington, CT 06032 |
Represented By
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| Docket last updated: 2 hours ago |
| Monday, May 13, 2024 | ||
| 44 | 44
motion
Protective Order
Mon 05/13 3:52 PM
Joint MOTION for Protective Order by Primacy, LLC.Responses due by 6/3/2024 (Hartley, Jill) |
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| 43 | 43
order
Order Referring Case to Magistrate Judge
Mon 05/13 9:16 AM
ORDER REFERRING CASE to Magistrate Judge Thomas O. Farrish for ruling on42 Consent MOTION for Extension of Time until June 14, 2024 to respond to Plaintiff Primacy, LLC's Complaint. Signed by Judge Jeffrey A. Meyer on 5/13/2024. |
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| Wednesday, May 08, 2024 | ||
| 42 | 42
motion
Extension of Time
Wed 05/08 2:18 PM
Consent MOTION for Extension of Time until June 14, 2024 to respond to Plaintiff Primacy, LLC's Complaint by Unlock Health. (Boskiewicz, Brett) |
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| Monday, May 06, 2024 | ||
| 41 | 41
order
Order on Motion to Seal
Mon 05/06 2:56 PM
ORDER GRANTING MOTION TO SEAL (Doc. #8 ). The Court GRANTS the motion to seal on the ground of compelling reasons for which sealing is narrowly tailored to serve. It is so ordered. Signed by Judge Jeffrey A. Meyer on 05/06/2024. (Parker, B.) |
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| Friday, May 03, 2024 | ||
| 40 | 40
order
Order on Motion for Extension of Time
Fri 05/03 2:03 PM
ORDER granting MOTION for Extension of Time until June 14, 2024 To Respond to Complaint (Doc. #39 ). Signed by Judge Jeffrey A. Meyer on 5/3/2024. (Lewis, D) |
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utility
Update Answer Deadline
Fri 05/03 2:05 PM
Answer deadline updated for Matt Cyr to 6/14/2024. (Lewis, D) |
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| Wednesday, May 01, 2024 | ||
| 39 | 39
motion
Extension of Time
Wed 05/01 1:37 PM
MOTION for Extension of Time until June 14, 2024 To Respond to Complaint by Matt Cyr. (Madsen, William) |
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| 38 | 38
3
pgs
order
Order
Wed 05/01 10:41 AM
ORDER: A Settlement Conference via Zoom is scheduled in this case for May 21, 2024 at 09:30 AM . Please see the attached Settlement Conference Order for detailed instructions and deadlines . Signed by Judge Robert M. Spector on May 1, 2024. (Spears, A) |
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utility
Calendar Entry
Wed 05/01 10:38 AM
NOTICE OF E-FILED CALENDAR: THIS IS THE ONLY NOTICE COUNSEL/THE PARTIES WILL RECEIVE. ALL PERSONS ENTERING THE COURTHOUSE MUST PRESENT PHOTO IDENTIFICATION. A Settlement Conference via Zoom is set for May 21, 2024 at 09:30 AM before Judge Robert M. Spector. (Spears, A) |
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| 36 | 36
minutes
Scheduling Conference
Wed 05/01 10:36 AM
Minute Entry for proceedings held before Judge Robert M. Spector: A telephonic Pre-Settlement Conference was held on 5/1/2024. 8 minutes. (Spears, A) |
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| Tuesday, April 30, 2024 | ||
| 35 | 35
service
Summons Returned Executed
Tue 04/30 1:31 PM
SUMMONS Returned Executed by Primacy, LLC. Unlock Health served on 4/23/2024, answer due 5/14/2024.(Hartley, Jill) |
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Att: 1
Affidavit of Process Server
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| 34 | 34
service
Summons Returned Executed
Tue 04/30 1:22 PM
SUMMONS Returned Executed by Primacy, LLC. Matt Cyr served on 4/23/2024, answer due 5/14/2024.(Hartley, Jill) |
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Att: 1
Affidavit Affidavit of Process Server
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| Friday, April 26, 2024 | ||
| 33 | 33
utility
Calendar Entry
Fri 04/26 3:24 PM
NOTICE OF E-FILED CALENDAR: THIS IS THE ONLY NOTICE COUNSEL/THE PARTIES WILL RECEIVE. ALL PERSONS ENTERING THE COURTHOUSE MUST PRESENT PHOTO IDENTIFICATION. A telephonic Pre-Settlement Conference is set for May 1, 2024 at 10:00 AM before Judge Robert M. Spector. A date for the settlement conference will be set during the telephone call. As the Court requires parties or their representatives with settlement authority to attend (in-person or by remote means) the settlement conference, counsel should obtain dates of unavailability from their clients over the next 60 days and have their own calendars available to aid in the scheduling. During the telephone call, counsel should be prepared to discuss what information needs to be exchanged and anything else that needs to be accomplished prior to the settlement conference for the discussions to be productive. Please use the following dial-in for this call: (877) 873-8017; Access Code: 7040261 . (Spears, A) |
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| 32 | 32
order
Order Referring Case to Magistrate Judge
Fri 04/26 2:32 PM
ORDER REFERRING CASE to Magistrate Judge Robert M. Spector for Settlement Conference. Signed by Judge Thomas O. Farrish on 4/26/24.(Wood, R.) |
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order
Order
Fri 04/26 12:57 PM
CONFERENCE MEMORANDUM AND ORDER. At today's telephonic scheduling conference, all parties agreed that they do not intend to go forward with the preliminary injunction hearing at this time. Nor do the defendants plan to challenge the temporary restraining order at present. The parties requested referral to another Magistrate Judge for purposes of a settlement conference. That request is GRANTED and the Clerk of the Court is respectfully directed to assign this matter to a random Magistrate Judge, other than the undersigned, for that purpose. If settlement negotiations are not successful and the parties wish to again take up the preliminary injunction or temporary restraining order, they should file a motion to that effect on the docket. So ordered. Signed by Judge Thomas O. Farrish on 4/26/24.(Wood, R.) |
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| 30 | 30
minutes
Scheduling Conference
Fri 04/26 12:56 PM
Minute Entry for proceedings held before Judge Thomas O. Farrish: Telephonic Scheduling Conference held on 4/26/2024. Time 6 minutes(Court Reporter Court Smart.) (Wood, R.) |
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| Thursday, April 25, 2024 | ||
| 29 | 29
notice
Notice of Appearance
Thu 04/25 5:02 PM
NOTICE of Appearance by William G. Madsen on behalf of Matt Cyr (Madsen, William) |
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| 28 | 28
misc
Disclosure Statement
Thu 04/25 1:32 PM
Disclosure Statement by Unlock Health identifying Corporate Parent Patient AER Buyer, Inc. for Unlock Health. (Boskiewicz, Brett) |
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| 27 | 27
notice
Notice of Appearance
Thu 04/25 1:28 PM
NOTICE of Appearance by Brett Boskiewicz on behalf of Unlock Health (Boskiewicz, Brett) |
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| Tuesday, April 23, 2024 | ||
| 26 | 26
utility
Calendar Entry
Tue 04/23 9:09 AM
NOTICE OF E-FILED CALENDAR: THIS IS THE ONLY NOTICE COUNSEL/THE PARTIES WILL RECEIVE. Telephonic Scheduling Conference set for 4/26/2024 at 11:00 AM before Judge Thomas O. Farrish. Please call in to the Court's conference call line at 1-888-557-8511 and enter the pass code of 4478772# when prompted. (Wood, R.) |
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| 25 | 25
order
Order
Tue 04/23 9:06 AM
MEMORANDUM OF CONFERENCE AND ORDER. Judge Farrish held a telephonic scheduling conference with the parties at 4:00 p.m. on April 22, 2024. Attorney Jill Hartley appeared for the plaintiff, Primacy, LLC. The defendant Matt Cyr appeared pro se . Attorneys Kamal Sleiman and Brett Boskiewicz of McDermott Will & Emery attended on behalf of the defendant Unlock Health, reserving their client's right to contest personal jurisdiction. In light of the time sensitivity of the issues to be discussed, the Court heard Attorneys Sleiman and Boskiewicz even though they have yet to file appearances in the case. But it respectfully directed them to file their appearances forthwith, or in the case of Attorney Sleiman, to file a motion for pro hac vice admission. Attorney Sleiman indicated that Unlock Health does not presently intend to disturb the temporary restraining order. Mr. Cyr was unable to state his views because he has not yet retained counsel. He stated that he expects to do so by close of business on Tuesday, April 23, 2024, and that he further expects that he and his counsel will be able to develop a position on the TRO/PI and associated scheduling issues by April 25, 2024. Accordingly, the Court reserved April 26, 2024 at 11:00 a.m. for another telephonic scheduling conference. A separate calendar entry will issue. Once Mr. Cyr has retained counsel, the parties are respectfully directed to confer about the plaintiff's application for a preliminary injunction and any scheduling issues associated therewith. If those discussions reveal that a scheduling conference on April 26 would be either premature or unnecessary, the parties are requested to notify the courtroom deputy, Mr. Robert Wood, at 860-240-3210, in which case the conference will be canceled or rescheduled as appropriate. It is so ordered. Signed by Judge Thomas O. Farrish on 4/23/24.(Wood, R.) |
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| Monday, April 22, 2024 | ||
| 23 | 23
minutes
Scheduling Conference
Mon 04/22 4:55 PM
Minute Entry for proceedings held before Judge Thomas O. Farrish: Telephonic Scheduling Conference held on 4/22/2024. Time 10 minutes(Court Reporter Court Smart.) (Wood, R.) |
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| 22 | 22
service
Electronic Summons Issued
Mon 04/22 9:54 AM
ELECTRONIC SUMMONS ISSUED in accordance with Fed. R. Civ. P. 4 and LR 4 as to *Matt Cyr, Unlock Health* with answer to complaint due within *21* days. Attorney *Jill Hartley* *Law Offices of Jill Hartley, LLC* *100 Pearl Street, 14th Floor* *Hartford, CT 06103*. (Freberg, B) |
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order
Electronic Service Documents
Mon 04/22 9:52 AM
NOTICE TO COUNSEL/SELF-REPRESENTED PARTIES : Counsel or self-represented parties initiating or removing this action are responsible for serving all parties with attached documents and copies of18 Electronic Filing Order,5 Affidavit,, filed by Primacy, LLC,9 Sealed Document filed by Primacy, LLC,20 Protective Order, 16 Order,, 15 Order,, 19 Calendar Entry,2 EXPARTE MOTION for Temporary Restraining Order and Preliminary Injunction filed by Primacy, LLC,13 Notice (Other) filed by Primacy, LLC, 11 Order,,10 Sealed Document filed by Primacy, LLC,7 Affidavit filed by Primacy, LLC,1 Complaint, filed by Primacy, LLC,17 Order on Pretrial Deadlines,6 Memorandum in Support of Motion filed by Primacy, LLC,8 MOTION to Seal Certain Exhibits to Declaration of Allison Minutillo filed by Primacy, LLC, 3 Notice re: Disclosure Statement,12 Order on ExParte Motion,,,,,,,, 14 Memorandum of Conference,,,,,4 Affidavit, filed by Primacy, LLC Signed by Clerk on 4/22/2024.(Freberg, B) |
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| 19 | 19
utility
Calendar Entry
Mon 04/22 9:49 AM
NOTICE OF E-FILED CALENDAR: THIS IS THE ONLY NOTICE COUNSEL/THE PARTIES WILL RECEIVE. Telephonic Scheduling Conference set for 4/22/2024 at 4:00 PM before Judge Thomas O. Farrish. Plaintiff's counsel is respectfully requested to provide the call-in information to any parties for whom an appearance has not yet been entered on the docket. Please call in to the Court's conference call line at 1-888-557-8511 and enter the pass code of 4478772# when prompted. (Wood, R.) |
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| Saturday, April 20, 2024 | ||
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order
Order
Sat 04/20 11:22 AM
AMENDED REFERRAL ORDER. The Court REFERS this action to Judge Farrish for purposes of setting a scheduling order concerning next steps in this litigation, any discovery to be conducted, and to conduct a preliminary injunction hearing if necessary and to issue a recommended ruling concerning a preliminary injunction. Consistent with the longstanding practices of the District of Connecticut, the Court encourages counsel to work cordially and professionally with one another and to consider to what extent they may agree as much as possible to avoid any unnecessary litigation and expense. It is so ordered. Signed by Judge Jeffrey A. Meyer on 04/20/2024. (Parker, B.) |
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| Friday, April 19, 2024 | ||
| 24 | 24
minutes
Status Conference
Mon 04/22 6:52 PM
Minute Entry for proceedings held before Judge Jeffrey A. Meyer: Telephonic Status Conference held on 4/19/2024. 07 minutes(Court Reporter Diana Huntington.) (Lewis, D) |
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order
Order
Fri 04/19 4:17 PM
ORDER OF REFERRAL TO MAGISTRATE JUDGE. The Court REFERS this action to Judge Farrish for purposes of setting a scheduling order concerning next steps in this litigation, any discovery to be conducted, and the scheduling of a preliminary injunction hearing. Consistent with the longstanding practices of the District of Connecticut, the Court encourages counsel to work cordially and professionally with one another and to consider to what extent they may agree as much as possible to avoid any unnecessary litigation and expense. It is so ordered. Signed by Judge Jeffrey A. Meyer on 04/19/2024. (Parker, B.) |
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order
Memorandum of Conference
Fri 04/19 4:15 PM
MEMORANDUM OF CONFERENCE AND ORDER. The Count convened a short teleconference today at which counsel for plaintiff Primacy, counsel for defendant Unlock Health, and Matt Cyr pro se participated. The Court confirmed that the defendants have received copies of the Court's TRO and that they will comply with the order. The Court advised Mr. Cyr that he should obtain counsel as soon as possible, and he stated that he is engaged in ongoing efforts to do so. The Court set a follow-up telephone status conference for 2:00pm on Monday, April 22, 2024 . Following the Court's status conference with the parties, Judge Meyer has consulted with Magistrate Judge Thomas O. Farrish who has been co-assigned to this case and who has agreed to preside in lieu of Judge Meyer over the next telephone status conference on Monday. The Court will enter a separate order referring this case to Judge Farrish for purposes of scheduling and discovery matters. The Court advises the parties of the possibility that Judge Farrish's chambers may contact them to adjust the time of the scheduling conference on Monday and to change the call-in number for the teleconference. Counsel for Primacy is requested to immediately forward a copy of this order to any parties for whom an appearance has not yet been entered on the docket. It is so ordered. Signed by Judge Jeffrey A. Meyer on 04/19/2024.(Parker, B) |
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| Thursday, April 18, 2024 | ||
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notice
Notice (Other)
Thu 04/18 9:10 PM
NOTICE by Primacy, LLC re12 Order on ExParte Motion,,,,,,,, Compliance with Notice Requirements of Order (Hartley, Jill) |
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order
Order on ExParte Motion
Thu 04/18 6:18 PM
ORDER GRANTING EX PARTE MOTION FOR TEMPORARY RESTRAINING ORDER. For the reasons set forth in the attached ruling, the Court GRANTS Primacy, LLC's ex parte motion for a temporary restraining order and issues the following orders: (1) Defendant Matt Cyr shall not work for defendant Unlock Health or any other entity that competes with Primacy in that it provides internet consulting services to a Primacy customer; (2) Defendant Matt Cyr shall maintain the confidentiality of all Confidential Information (as that term is defined in his former contract with Primacy) and not disclose such Confidential Information to any third party, including to defendant Unlock Health and/or any of defendant Unlock Health's employees; and (3) Defendants Matt Cyr and Unlock Health shall not discard, destroy, or dispose of any evidence or other materials, in any form, relating to this action and the issues raised herein; and (4) Defendant Unlock Health shall not make use of any Confidential Information (as that term is defined in defendant Matt Cyr's former contract with Primacy) relating to Primacy's business that was obtained by defendant Matt Cyr in the course of his employment and which is in the possession of defendant Matt Cyr and/or defendant Unlock Health. Primacy shall immediately serve by email a copy of its complaint, its motion for a temporary restraining order, all supporting papers, and this order on the defendants. Primacy shall file on the docket by 10:00am on April 19, 2024 a confirmation that the defendants have been served. These orders shall remain in effect pending the Court's hearing on Primacy's motion for preliminary injunction and without prejudice in the meantime to the defendants' filing of any motion to vacate or modify this order. The Court has scheduled a telephone status conference for 3:00pm on April 19, 2024 to hear from the defendants and to set forth a schedule concerning further proceedings. It is so ordered. Signed by Judge Jeffrey A. Meyer on 04/18/2024. (Parker, B.) |
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order
Order
Thu 04/18 1:25 PM
ORDER. The Court shall conduct a telephone status conference at 3:00pm on April 19, 2024. Chambers has received an unsolicited telephone inquiry from counsel who state they represent the defendants and are aware of this action. If counsel for plaintiff is aware of counsel for defendants, counsel for plaintiff should advise defense counsel of the telephone status conference. The parties are instructed to call 877-402-9753 for the conference; Access Code 8576007#. It is so ordered. Signed by Judge Jeffrey A. Meyer on 04/18/2024. (Parker, B.) |
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| Wednesday, April 17, 2024 | ||
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order
Protective Order
Mon 04/22 9:50 AM
STANDING PROTECTIVE ORDER Signed by Judge Jeffrey A. Meyer on 4/17/2024.(Freberg, B) |
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order
Electronic Filing Order
Mon 04/22 9:48 AM
ELECTRONIC FILING ORDER FOR COUNSEL - PLEASE ENSURE COMPLIANCE WITH COURTESY COPY REQUIREMENTS IN THIS ORDER Signed by Judge Jeffrey A. Meyer on 4/17/2024.(Freberg, B) |
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| 17 | 17
1
pgs
order
Order on Pretrial Deadlines
Mon 04/22 9:48 AM
Order on Pretrial Deadlines: Amended Pleadings due by 6/16/2024 Discovery due by 10/17/2024 Dispositive Motions due by 11/21/2024 Signed by Clerk on 4/17/2024.(Freberg, B) |
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| 10 | 10
misc
Sealed Document
Wed 04/17 3:36 PM
Sealed Document: Unredacted Exhibits by Primacy, LLC re8 MOTION to Seal Certain Exhibits to Declaration of Allison Minutillo . (Hartley, Jill) |
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| 9 | 9
misc
Sealed Document
Wed 04/17 3:12 PM
Sealed Document: Redacted Exhibits by Primacy, LLC re8 MOTION to Seal Certain Exhibits to Declaration of Allison Minutillo . (Hartley, Jill) |
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motion
Seal
Wed 04/17 2:59 PM
MOTION to Seal Certain Exhibits to Declaration of Allison Minutillo by Primacy, LLC. (Hartley, Jill) |
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misc
Affidavit
Wed 04/17 2:07 PM
AFFIDAVIT re2 EXPARTE MOTION for Temporary Restraining Order and Preliminary Injunction Signed By Jill Hartley filed by Primacy, LLC. (Hartley, Jill) |
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30+
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respm
Memorandum in Support of Motion
Wed 04/17 2:00 PM
Memorandum in Support re2 EXPARTE MOTION for Temporary Restraining Order and Preliminary Injunction filed by Primacy, LLC. (Hartley, Jill) |
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misc
Affidavit
Wed 04/17 1:52 PM
AFFIDAVIT re2 EXPARTE MOTION for Temporary Restraining Order and Preliminary Injunction Signed By Allison Minutillo filed by Primacy, LLC.(Hartley, Jill) |
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Att: 1
Exhibit Exhibit A,
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Exhibit Exhibit B,
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Exhibit Exhibit C,
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Att: 4
Exhibit Exhibit D,
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Att: 5
Exhibit Exhibit E,
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Att: 6
Exhibit Exhibit F,
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Att: 7
Exhibit Exhibit G,
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Att: 8
Exhibit Exhibit H,
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Att: 9
Exhibit Exhibit I,
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Att: 10
Exhibit Exhibit J,
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Att: 11
Exhibit Exhibit K,
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Att: 12
Exhibit Exhibit L,
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Att: 13
Exhibit Exhibit L-1,
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Att: 14
Exhibit Exhibit M,
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Att: 15
Exhibit Exhibit N
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misc
Affidavit
Wed 04/17 1:27 PM
AFFIDAVIT re2 EXPARTE MOTION for Temporary Restraining Order and Preliminary Injunction Signed By Stanley Valencis filed by Primacy, LLC.(Hartley, Jill) |
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Att: 1
Exhibit Exhibit A,
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Att: 2
Exhibit Exhibit B,
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Att: 3
Exhibit Exhibit C,
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Att: 4
Exhibit Exhibit C-1,
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Att: 5
Exhibit Exhibit C-2,
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Att: 6
Exhibit Exhibit C-3,
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Att: 7
Exhibit Exhibit D,
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Att: 8
Exhibit Exhibit E,
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Att: 9
Exhibit Exhibit F
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motion
ExParte Motion
Wed 04/17 12:52 PM
EXPARTE MOTION for Temporary Restraining Order and Preliminary Injunction by Primacy, LLC. (Hartley, Jill) |
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47
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cmp
Complaint
Wed 04/17 12:05 PM
COMPLAINT against All Defendants ( Filing fee $405 receipt number ACTDC-7725748.), filed by Primacy, LLC.(Hartley, Jill) |
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Att: 1
Exhibit Exhibit A,
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Att: 2
Exhibit Exhibit B,
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Att: 3
Exhibit Exhibit C,
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Att: 4
Exhibit Exhibit D,
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Att: 5
Exhibit Exhibit E,
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Att: 6
Exhibit Exhibit F
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service
Request to Issue Summons
Wed 04/17 12:09 PM
Request for Clerk to issue summons as to All Defendants. (Hartley, Jill) |
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notice
Notice re: Disclosure Statement
Wed 04/17 12:56 PM
Notice: Pursuant to Federal Rule of Civil Procedure 7.1, a disclosure statement must be filed with a party's first appearance, pleading, petition, motion, response, or other request addressed to the Court and must be supplemented if any required information changes during the case. Signed by Clerk on 4/17/2024.(Maturo, F.) |
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utility
Add and Terminate Judges
Wed 04/17 1:04 PM
Judge Jeffrey A. Meyer and Judge Thomas O. Farrish added. (Oliver, T.) |
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