Safeguard Solutions, Inc. v. Wireless Guardian Inc. et al
| Pennsylvania Middle District Court | |
| Judge: | Christopher C Conner |
| Case #: | 1:24-cv-01392 |
| Nature of Suit | 190 Contract - Other Contract |
| Cause | 18:1961 Racketeering (RICO) Act |
| Case Filed: | Aug 19, 2024 |
| Terminated: | Dec 11, 2024 |
| Last checked: Saturday Feb 15, 2025 3:58 AM EST |
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Defendant
Jason Dumas
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Defendant
Dwayne Ratliff
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Defendant
Wireless Guardian Inc.
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Defendant
Southeastern Wireless Solutions LLC
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Plaintiff
Safeguard Solutions, Inc.
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Represented By
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| TERMINATED PARTIES | |
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Defendant
James Cunningham
Terminated: 12/11/2024
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Represented By
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Defendant
Cunningham and McGinley Consultants LLC
Terminated: 12/11/2024
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Represented By
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| Docket last updated: 05/08/2025 11:59 PM EDT |
| Wednesday, December 11, 2024 | ||
| 30 | 30
misc
Stipulation of Dismissal
Wed 12/11 4:06 PM
STIPULATION of Dismissal Joint Stipulation to Dismiss Case Without Prejudice by Safeguard Solutions, Inc.. (Shulsky, Terry) |
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misc
Docket Annotation
Wed 12/11 4:15 PM
DOCKET ANNOTATION: Case CLOSED pursuant to stipulation30 of dismissal. (mw) |
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| Tuesday, December 10, 2024 | ||
| 29 | 29
misc
Stipulation
Wed 12/11 10:49 AM
JOINT STIPULATION OF DISMISSAL WITH PREJUDICE by Safeguard Solutions, Inc., Cunningham and McGinley Consultants LLC, James Cunningham. (ma) |
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| 28 | 28
notice
Attorney Appearance - Entry of Appearance
Tue 12/10 3:44 PM
NOTICE of Appearance by Christopher D. Carusone on behalf of Cunningham and McGinley Consultants LLC (Carusone, Christopher) |
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| Tuesday, November 26, 2024 | ||
| 27 | 27
1
pgs
order
Order on Motion to Withdraw as Attorney
Tue 11/26 4:16 PM
ORDER granting26 Motion to Withdraw as Attorney. Attorney Justin G. Weber terminated. Signed by Honorable Christopher C. Conner on 11/26/2024 (mw) |
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| 26 | 26
motion
Withdraw as Attorney
Tue 11/26 3:32 PM
MOTION to Withdraw as Attorney by Safeguard Solutions, Inc..(Weber, Justin) |
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Att: 1
Proposed Order
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| Tuesday, November 19, 2024 | ||
| 25 | 25
23
pgs
respm
Brief in Support (Do not use for Summary Judgment Motions)
Tue 11/19 9:23 AM
BRIEF IN SUPPORT re24 MOTION to Dismiss for Failure to State a Claim filed by James Cunningham.(Stolarz, Brian) |
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Att: 1
Exhibit(s),
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Att: 2
Proposed Order
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misc
Docket Annotation
Tue 11/19 8:27 AM
DOCKET ANNOTATION: Counsel is advised to file the brief in support for document 24 as a separate docket entry. (mw) |
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| Monday, November 18, 2024 | ||
| 24 | 24
motion
Dismiss for Failure to State a Claim
Mon 11/18 4:49 PM
MOTION to Dismiss for Failure to State a Claim by James Cunningham.(Stolarz, Brian) |
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Att: 1
Exhibit(s),
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Att: 2
Proposed Order
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| Monday, October 21, 2024 | ||
| 23 | 23
service
Summons Issued
Mon 10/21 2:08 PM
Summons Issued as to Cunningham and McGinley Consultants LLC, Southeastern Wireless Solutions LLC and provided TO ATTORNEY ELECTRONICALLY VIA ECF for service on Defendant(s)in the manner prescribed by Rule 4 of the Federal Rules of Civil Procedure. (NOTICE TO ATTORNEYS RECEIVING THE SUMMONS ELECTRONICALLY: You must print the summons and the attachment when you receive it in your e-mail and serve the complaint on all defendants in the manner prescribed by Rule 4 of the Federal Rules of Civil Procedure). (ll) |
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Att: 1
8 pgs
Summons Packet
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| Friday, October 18, 2024 | ||
| 22 | 22
76
pgs
cmp
Amended Complaint
Fri 10/18 4:19 PM
AMENDED COMPLAINT against James Cunningham, Jason Dumas, Dwayne Ratliff, Wireless Guardian Inc., Cunningham and McGinley Consultants LLC, Southeastern Wireless Solutions LLC, filed by Safeguard Solutions, Inc..(Weber, Justin) |
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Att: 1
Exhibit(s) A,
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Att: 2
Exhibit(s) B,
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Att: 3
Exhibit(s) C,
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Att: 4
Exhibit(s) D,
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Att: 5
Exhibit(s) E,
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Att: 6
Exhibit(s) F,
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Att: 7
Exhibit(s) G,
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Att: 8
Exhibit(s) H,
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Att: 9
Exhibit(s) I,
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Att: 10
41 pgs
Exhibit(s) J
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| Wednesday, October 16, 2024 | ||
| 21 | 21
2
pgs
order
Order on Motion for Extension of Time to Answer
Wed 10/16 2:48 PM
ORDER granting19 Motion for Extension of Time to Answer - Defendants Wireless Guardian Inc., Dwayne Ratliff, and James Cunningham a/k/a Jimmy Cunningham shall have thirty (30) days to answer, move, or otherwise respond to the filing of an Amended Complaint by Plaintiff Safeguard in the above-captioned matter. The page limit for any briefs in support of their motions to dismiss the Amended Complaint shall be extended to no more than 6,500 words. Signed by Honorable Christopher C. Conner on 10/16/2024 (mw) |
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| 20 | 20
4
pgs
order
Special Admissions Form Approved
Wed 10/16 2:21 PM
SPECIAL ADMISSIONS FORM APPROVED as to Brian W. Stolarz. Signed by Honorable Christopher C. Conner on 10/16/2024. (mw) |
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| 19 | 19
motion
Extension of Time to File Answer
Wed 10/16 12:57 PM
Joint MOTION for Extension of Time to File Answer re1 Complaint,,, and Expansion of Word Count by Safeguard Solutions, Inc..(Weber, Justin) |
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Att: 1
Proposed Order
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| Tuesday, October 15, 2024 | ||
| 18 | 18
misc
Petition for Special Admission - Pro Hac Vice
Tue 10/15 5:14 PM
PETITION FOR SPECIAL ADMISSION (PRO HAC VICE) by Brian W. Stolarz on behalf of James Cunningham Attorney Brian Stolarz is seeking special admission Filing fee $ 50, receipt number APAMDC-6786592.. (Stolarz, Brian) |
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| Wednesday, September 25, 2024 | ||
| 17 | 17
2
pgs
order
Order on Motion to Vacate
Wed 09/25 9:51 AM
ORDER granting16 Joint MOTION to Vacate14 Clerk's Entry of Default,15 Clerk's Entry of Default without Prejudice as to Defendants, Wireless Guardian, Inc., and Dwayne Ratcliff . Signed by Honorable Christopher C. Conner on 9/25/2024 (mw) |
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| Tuesday, September 24, 2024 | ||
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3
pgs
motion
Vacate
Tue 09/24 4:51 PM
Joint MOTION to Vacate14 Clerk's Entry of Default,15 Clerk's Entry of Default without Prejudice as to Defendants, Wireless Guardian, Inc., and Dwayne Ratcliff by Safeguard Solutions, Inc..(Shulsky, Terry) |
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Att: 1
Proposed Order Exhibit A
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| Thursday, September 19, 2024 | ||
| 15 | 15
1
pgs
order
Clerk's Entry of Default
Thu 09/19 4:50 PM
Clerk's ENTRY OF DEFAULT as to Wireless Guardian Inc. (ma) |
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| 14 | 14
order
Clerk's Entry of Default
Thu 09/19 4:42 PM
Clerk's ENTRY OF DEFAULT as to Dwayne Ratliff (ma) |
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| 13 | 13
3
pgs
motion
Entry of Default
Thu 09/19 4:24 PM
MOTION for Entry of Default as to Defendant, Wireless Guardian, Inc. by Safeguard Solutions, Inc..(Shulsky, Terry) |
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Att: 1
Affidavit Exhibit A,
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Att: 2
Proposed Order
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| 12 | 12
motion
Entry of Default
Thu 09/19 4:18 PM
MOTION for Entry of Default as to Defendant, Dwayne Ratliff by Safeguard Solutions, Inc..(Shulsky, Terry) |
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Att: 1
Affidavit Exhibit A,
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Att: 2
Proposed Order
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| Monday, September 16, 2024 | ||
| 11 | 11
order
Verbal Order on Motion(s) Order on Motion for Extension of Time to Answer
Mon 09/16 3:19 PM
VERBAL ORDER - It is ORDERED that the motion10 is GRANTED and movant shall have until October 18, 2024, to answer or otherwise respond to the complaint. Signed by Honorable Christopher C. Conner on 9/16/2024. (Text-only entry; no PDF document will issue. This text-only entry constitutes the order of the court or notice on the matter.) (mw) |
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| 10 | 10
2
pgs
motion
Extension of Time to File Answer
Mon 09/16 3:08 PM
Consent MOTION for Extension of Time to File Answer re1 Complaint,,, by James Cunningham.(Callahan, Colin) |
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Att: 1
Proposed Order
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| Tuesday, September 10, 2024 | ||
| 9 | 9
1
pgs
service
Summons Returned Executed
Tue 09/10 9:01 AM
SUMMONS Returned Executed by Safeguard Solutions, Inc.. James Cunningham served on 8/28/2024, answer due 9/18/2024. (Schueller, Christopher) |
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| 8 | 8
1
pgs
service
Summons Returned Executed
Tue 09/10 8:58 AM
SUMMONS Returned Executed by Safeguard Solutions, Inc.. Wireless Guardian Inc. served on 8/28/2024, answer due 9/18/2024. (Schueller, Christopher) |
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| 7 | 7
1
pgs
service
Summons Returned Executed
Tue 09/10 8:55 AM
SUMMONS Returned Executed by Safeguard Solutions, Inc.. Dwayne Ratliff served on 8/28/2024, answer due 9/18/2024. (Schueller, Christopher) |
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| Thursday, August 29, 2024 | ||
| 6 | 6
4
pgs
order
Special Admissions Form Approved
Thu 08/29 9:11 AM
SPECIAL ADMISSIONS FORM APPROVED as to Christopher Schueller. Signed by Honorable Christopher C. Conner on 8/29/2024. (mw) |
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| Wednesday, August 28, 2024 | ||
| 5 | 5
2
pgs
misc
Corporate Disclosure Statement
Wed 08/28 2:09 PM
Corporate Disclosure Statement by Safeguard Solutions, Inc.. (Shulsky, Terry) |
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| 4 | 4
3
pgs
misc
Petition for Special Admission - Pro Hac Vice
Wed 08/28 2:06 PM
PETITION FOR SPECIAL ADMISSION (PRO HAC VICE) by Christopher P. Schueller on behalf of Safeguard Solutions, Inc. Attorney Christopher P. Schueller is seeking special admission Filing fee $ 50, receipt number APAMDC-6741154..(Schueller, Christopher) |
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Att: 1
1 pgs
Listing of Christopher P. Schueller's Admissions
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| Monday, August 19, 2024 | ||
| 3 | 3
2
pgs
order
Order Re: Case Assignment and Procedures
Mon 08/19 3:10 PM
ORDER Re: Case Assignment and Procedures. Signed by Honorable Christopher C. Conner on 8/19/2024. (mw) |
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| 2 | 2
2
pgs
service
Summons Issued
Mon 08/19 1:33 PM
Summons Issued as to All Defendants and provided TO ATTORNEY ELECTRONICALLY VIA ECF for service on Defendant(s)in the manner prescribed by Rule 4 of the Federal Rules of Civil Procedure. (NOTICE TO ATTORNEYS RECEIVING THE SUMMONS ELECTRONICALLY: You must print the summons and the attachment when you receive it in your e-mail and serve the complaint on all defendants in the manner prescribed by Rule 4 of the Federal Rules of Civil Procedure). (ibr) |
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Att: 1
5 pgs
Summons Packet
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| 1 | 1
26
pgs
cmp
Complaint
Mon 08/19 1:32 PM
COMPLAINT against All Defendants ( Filing fee $405, Receipt Number APAMDC-6729776), filed by Safeguard Solutions, Inc.. (ibr) |
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Att: 1
1 pgs
Civil Cover Sheet,
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Att: 2
35 pgs
Exhibit A - Reseller Agreement,
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Att: 3
12 pgs
Exhibit B - Master Services Agreement,
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Att: 4
29 pgs
Exhibit C - Wireless Guardian Purchases Summary,
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Att: 5
32 pgs
Exhibit D - Statements of Revenue Summary,
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Att: 6
24 pgs
Exhibit E - Weekly Meetings Summary,
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Att: 7
6 pgs
Exhibit F - Letter from the CEO,
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Att: 8
2 pgs
Exhibit G - Wireless Guardian Executive Memo - Statement from the Board of Directors,
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Att: 9
2 pgs
Exhibit H - Wireless Guardian Executive Memo - Letter on the Status of the Chairman,
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Att: 10
3 pgs
Exhibit I - Wireless Guardian Executive Memo - Statement from the CEO,
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Att: 11
11 pgs
Exhibit J - Safeguard Solutions Financials
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misc
Docket Annotation
Mon 08/19 1:34 PM
DOCKET ANNOTATION: Attorney Schueller can find information regarding either general or special admission at https://www.pamd.uscourts.gov/forms/petition-admission-practice. (ibr) |
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