CHANG et al v. REPUBLIC OF SOUTH SUDAN et al
| District Of Columbia District Court | |
| Judge: | Rudolph Contreras |
| Case #: | 1:21-cv-01821 |
| Nature of Suit | 890 Other Statutes - Other Statutory Actions |
| Cause | 28:1605A Foreign Sovereign Immunities Act |
| Case Filed: | Jul 08, 2021 |
| Last checked: Tuesday Jan 04, 2022 3:28 AM EST |
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Defendant
SOUTH SUDAN MINISTRY OF DEFENCE AND VETERAN AFFAIRS
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Defendant
REPUBLIC OF SOUTH SUDAN
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Plaintiff
NATALIE CHANG
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Represented By
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Plaintiff
REBECCA CHOL NYGUNDENG
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Represented By
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Plaintiff
JANE DOE
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Represented By
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Plaintiff
JEANA GRAHAM
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Represented By
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Plaintiff
GIAN LIBOT
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Represented By
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Plaintiff
MARY ROE
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Represented By
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Plaintiff
IRENE SCOTT
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Represented By
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GPO
Mar 03 2023
MEMORANDUM OPINION granting 25 Defendants' Motion to Dismiss. See document for details. Signed by Judge Rudolph Contreras on 3/3/2023. (lcrc1) |
| Docket last updated: 9 hours ago |
| Friday, March 03, 2023 | ||
| 36 | 36
14
pgs
order
Memorandum & Opinion
Fri 03/03 12:44 PM
MEMORANDUM OPINION granting25 Defendants' Motion to Dismiss. See document for details. Signed by Judge Rudolph Contreras on 3/3/2023. (lcrc1) |
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1
pgs
order
Order on Motion to Dismiss
Fri 03/03 12:43 PM
ORDER granting25 Defendants' Motion to Dismiss. See document for details. Signed by Judge Rudolph Contreras on 3/3/2023. (lcrc1) |
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| Monday, January 23, 2023 | ||
| 34 | 34
notice
Notice of Voluntary Dismissal/Party
Mon 01/23 10:43 AM
NOTICE of Voluntary Dismissal re Rebecca Chol Nygundeng Rule 41 Dismissal With Prejudice (Gilmore, Scott) |
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| Thursday, October 13, 2022 | ||
| 33 | 33
notice
Notice of Related Case
Thu 10/13 5:22 PM
NOTICE OF RELATED CASE by All Defendants. Case related to Case No. 22-CV-2769-TNM.(Levin, Duncan) |
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Att: 1
Exhibit Bunch Complaint
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| 32 | 32
notice
Notice of Related Case
Thu 10/13 1:50 PM
ENTERED IN ERROR.....NOTICE OF RELATED CASE by All Defendants. Case related to Case No. 22-2769 (Levin, Duncan) Modified on 10/13/2022 (ztth) |
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Att: 1
Exhibit Complaint in Bunch et al.
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notice
Notice of Error
Thu 10/13 4:26 PM
NOTICE OF ERROR regarding32 Notice of Related Case. The following error(s) need correction: Incorrect format (Letter) - correspondence is not permitted (LCvR 5.1(a)). Please refile. (ztth) |
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| Wednesday, June 29, 2022 | ||
| 31 | 31
respm
Surreply
Wed 06/29 4:37 PM
SURREPLY to re25 MOTION to Dismiss Complaint filed by NATALIE CHANG, REBECCA CHOL NYGUNDENG, JANE DOE, JEANA GRAHAM, GIAN LIBOT, MARY ROE, IRENE SCOTT. (Gilmore, Scott) |
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| Thursday, June 23, 2022 | ||
| 30 | 30
motion
Leave to File Document
Thu 06/23 7:12 PM
Unopposed MOTION for Leave to File Sur-Reply in Response to New Defense Raised in Defendants' Reply by NATALIE CHANG, REBECCA CHOL NYGUNDENG, JANE DOE, JEANA GRAHAM, GIAN LIBOT, MARY ROE, IRENE SCOTT.(Gilmore, Scott) |
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Att: 1
Text of Proposed Order
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order
Order on Motion for Leave to File
Thu 06/23 9:00 PM
MINUTE ORDER granting30 Plaintiffs' Unopposed Motion for Leave to File Sur-reply: It is hereby ORDERED that Plaintiffs may file a sur-reply to respond to29 Defendants' reply in support of their motion to dismiss. It is further ORDERED that the sur-reply shall be limited to the length and content proposed in Plaintiffs' motion for leave to file. SO ORDERED. Signed by Judge Rudolph Contreras on 06/23/2022. (lcrc1) |
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| Monday, June 20, 2022 | ||
| 29 | 29
respm
Reply to opposition to motion
Mon 06/20 9:42 AM
REPLY to opposition to motion re25 MOTION to Dismiss Complaint filed by REPUBLIC OF SOUTH SUDAN, SOUTH SUDAN MINISTRY OF DEFENCE AND VETERAN AFFAIRS. (Levin, Duncan) |
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| Wednesday, June 08, 2022 | ||
| 28 | 28
motion
Extension of Time to File Response/Reply
Wed 06/08 2:57 PM
MOTION for Extension of Time to File Response/Reply by REPUBLIC OF SOUTH SUDAN, SOUTH SUDAN MINISTRY OF DEFENCE AND VETERAN AFFAIRS.(Levin, Duncan) |
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Att: 1
Text of Proposed Order
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order
Order on Motion for Extension of Time to File Response/Reply
Wed 06/08 5:40 PM
ORDER granting28 Defendants' Unopposed Motion for Extension of Time: It is hereby ORDERED that Defendants shall file their reply in support of25 Defendants' Motion to Dismiss on or before June 20, 2022. SO ORDERED. Signed by Judge Rudolph Contreras on 06/08/2022. (lcrc1) |
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| Monday, June 06, 2022 | ||
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27
pgs
respm
Memorandum in opposition to motion
Mon 06/06 2:08 PM
Memorandum in opposition to re25 MOTION to Dismiss Complaint filed by NATALIE CHANG, REBECCA CHOL NYGUNDENG, JANE DOE, JEANA GRAHAM, GIAN LIBOT, MARY ROE, IRENE SCOTT.(Gilmore, Scott) |
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Att: 1
Text of Proposed Order Proposed Order on Motion to Dismiss
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| Thursday, May 19, 2022 | ||
| 26 | 26
motion
Extension of Time to File Response/Reply
Thu 05/19 12:25 PM
MOTION for Extension of Time to File Response/Reply as to25 MOTION to Dismiss Complaint by NATALIE CHANG, REBECCA CHOL NYGUNDENG, JANE DOE, JEANA GRAHAM, GIAN LIBOT, MARY ROE, IRENE SCOTT.(Gilmore, Scott) |
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Att: 1
Text of Proposed Order
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order
Order on Motion for Extension of Time to File Response/Reply
Thu 05/19 12:49 PM
MINUTE ORDER granting26 Plaintiffs' Unopposed Motion for Extension of Time: It is hereby ORDERED that Plaintiffs shall file their opposition to25 Defendants' Motion to Dismiss on or before June 8, 2022. SO ORDERED. Signed by Judge Rudolph Contreras on 05/19/2022. (lcrc1) |
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| Wednesday, May 11, 2022 | ||
| 25 | 25
motion
Dismiss
Wed 05/11 5:19 PM
MOTION to Dismiss Complaint by REPUBLIC OF SOUTH SUDAN, SOUTH SUDAN MINISTRY OF DEFENCE AND VETERAN AFFAIRS.(Sullivan, Ronald) |
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Att: 1
Memorandum in Support
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| Tuesday, April 19, 2022 | ||
| 24 | 24
misc
Status Report
Tue 04/19 10:06 AM
Joint STATUS REPORT by NATALIE CHANG, REBECCA CHOL NYGUNDENG, JANE DOE, JEANA GRAHAM, GIAN LIBOT, MARY ROE, IRENE SCOTT. (Gilmore, Scott) |
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order
.Order
Tue 04/19 11:24 AM
MINUTE ORDER: Upon consideration of24 the parties' joint status report, it is hereby ORDERED that Defendants shall file an answer or otherwise respond to1 the Complaint on or before May 15, 2022. SO ORDERED. Signed by Judge Rudolph Contreras on 04/19/2022. (lcrc1) |
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| Wednesday, April 13, 2022 | ||
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order
.Order
Wed 04/13 5:25 PM
MINUTE ORDER: It is hereby ORDERED that the parties shall submit a joint status report on or before April 27, 2022. SO ORDERED. Signed by Judge Rudolph Contreras on 04/13/2022. (lcrc1) |
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| Friday, January 28, 2022 | ||
| 23 | 23
notice
Notice of Appearance
Fri 01/28 12:44 PM
NOTICE of Appearance by Duncan P. Levin on behalf of All Defendants (Levin, Duncan) |
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| Thursday, January 27, 2022 | ||
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order
Order on Motion to Set Aside Default
Thu 01/27 10:14 AM
MINUTE ORDER granting22 Defendants' Unopposed Motion to Set Aside Default: Upon consideration of22 Defendants' Unopposed Motion to Set Aside Default, and pursuant to Federal Rule of Civil Procedure 55(c), it is hereby ORDERED that16 the Clerk's Entry of Default is VACATED. It is further ORDERED that Defendants shall answer or otherwise respond to the Complaint on or before March 28, 2022. SO ORDERED. Signed by Judge Rudolph Contreras on 01/27/2022. (lcrc1) |
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| Wednesday, January 26, 2022 | ||
| 22 | 22
motion
Set Aside Default
Wed 01/26 8:03 PM
Unopposed MOTION to Set Aside Default by REPUBLIC OF SOUTH SUDAN, SOUTH SUDAN MINISTRY OF DEFENCE AND VETERAN AFFAIRS. (Sullivan, Ronald) |
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| Tuesday, January 18, 2022 | ||
| 21 | 21
notice
Notice of Withdrawal of Appearance
Tue 01/18 10:56 AM
NOTICE OF WITHDRAWAL OF APPEARANCE as to NATALIE CHANG, REBECCA CHOL NYGUNDENG, JANE DOE, JEANA GRAHAM, GIAN LIBOT, MARY ROE, IRENE SCOTT. Attorney Jeanette Bayoumi terminated. (Bayoumi, Jeanette) |
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notice
Notice of QC
Tue 01/18 10:42 AM
NOTICE OF ERROR re19 Motion for Leave to Appear Pro Hac Vice; emailed to rsullivan@ronaldsullivanlaw.com, cc'd 5 associated attorneys -- The PDF file you docketed contained errors: 1. Please refile document, 2. The Declaration require ink signatures. Please refile the Declaration with ink signatures as an Errata and attach the Declaration. (ztth, ) |
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| Monday, January 17, 2022 | ||
| 20 | 20
motion
Appear Pro Hac Vice
Mon 01/17 11:23 AM
Amended MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Duncan Levin, Filing fee $ 100, receipt number ADCDC-8983080. Fee Status: Fee Paid. by REPUBLIC OF SOUTH SUDAN, SOUTH SUDAN MINISTRY OF DEFENCE AND VETERAN AFFAIRS. (Sullivan, Ronald) |
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order
Order on Motion for Leave to Appear Pro Hac Vice
Mon 01/17 9:35 AM
MINUTE ORDER denying without prejudice19 Motion for Admission Pro Hac Vice : The declaration in support of the motion for admission pro hac vice does not comply with all relevant local rules. An application for admission pro hac vice must include "a certification that the attorney either has or has not been disciplined by any bar, and if the attorney has been disciplined by any bar, the circumstances and details of the discipline" (D.D.C. Civ. R. 83.2(d)(4)). It is hereby ORDERED that19 the Motion for Admission Pro Hac Vice is DENIED WITHOUT PREJUDICE. SO ORDERED. Signed by Judge Rudolph Contreras on 01/17/2022. (lcrc1) |
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order
Order on Motion for Leave to Appear Pro Hac Vice
Mon 01/17 11:52 AM
MINUTE ORDER granting20 Motion for Leave to Appear Pro Hac Vice : Pursuant to Local Civil Rule 83.2, it is hereby ORDERED that Duncan Levin is admitted to represent Defendants pro hac vice in this case. Counsel should register for e-filing via PACER and file a notice of appearance pursuant to LCvR 83.6(a). Click for instructions . SO ORDERED. Signed by Judge Rudolph Contreras on 01/17/2022. (l crc1) |
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| Friday, January 14, 2022 | ||
| 19 | 19
motion
Appear Pro Hac Vice
Fri 01/14 3:09 PM
MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Duncan Levin, Filing fee $ 100, receipt number ADCDC-8981827. Fee Status: Fee Paid. by REPUBLIC OF SOUTH SUDAN. (Sullivan, Ronald) |
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notice
Notice of Appearance
Fri 01/14 2:33 PM
NOTICE of Appearance by Ronald S. Sullivan, Jr on behalf of All Defendants (Sullivan, Ronald) |
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| Wednesday, November 17, 2021 | ||
| 17 | 17
misc
Status Report
Wed 11/17 9:36 AM
STATUS REPORT by NATALIE CHANG, REBECCA CHOL NYGUNDENG, JANE DOE, JEANA GRAHAM, GIAN LIBOT, MARY ROE, IRENE SCOTT. (Gilmore, Scott) |
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| Friday, November 05, 2021 | ||
| 16 | 16
misc
Clerks Entry of Default
Fri 11/05 3:31 PM
Clerk's ENTRY OF DEFAULT as to REPUBLIC OF SOUTH SUDAN, SOUTH SUDAN MINISTRY OF DEFENCE AND VETERAN AFFAIRS (ztth) |
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| Tuesday, November 02, 2021 | ||
| 15 | 15
misc
Status Report
Tue 11/02 3:42 PM
STATUS REPORT by NATALIE CHANG, REBECCA CHOL NYGUNDENG, JANE DOE, JEANA GRAHAM, GIAN LIBOT, MARY ROE, IRENE SCOTT. (Gilmore, Scott) |
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| 14 | 14
misc
Affidavit for Default
Tue 11/02 3:37 PM
AFFIDAVIT FOR DEFAULT re11 Summons Returned Executed as to foreign state or agency,1 Complaint,, Declaration of Scott A. Gilmore in Support of Entry of Default Against Defendants Republic of South Sudan and South Sudan Ministry of Defence and Veteran Affairs by NATALIE CHANG, REBECCA CHOL NYGUNDENG, JANE DOE, JEANA GRAHAM, GIAN LIBOT, MARY ROE, IRENE SCOTT.(Gilmore, Scott) |
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Att: 1
Exhibit A - 10/18/2021 Email Correspondence to Counsel Kuol
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| Monday, September 13, 2021 | ||
| 13 | 13
notice
Notice of Appearance
Mon 09/13 2:13 PM
NOTICE of Appearance by Jeanette Bayoumi on behalf of All Plaintiffs (Bayoumi, Jeanette) |
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| Wednesday, September 08, 2021 | ||
| 12 | 12
notice
Notice of Appearance
Wed 09/08 11:00 AM
NOTICE of Appearance by James Gotz on behalf of All Plaintiffs (Gotz, James) |
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| Tuesday, August 31, 2021 | ||
| 11 | 11
service
Summons Returned Executed as to Foreign State or Agency
Tue 08/31 3:40 PM
RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed as to REPUBLIC OF SOUTH SUDAN served on 8/23/2021, answer due 10/22/2021; SOUTH SUDAN MINISTRY OF DEFENCE AND VETERAN AFFAIRS served on 8/23/2021, answer due 10/22/2021.(Gilmore, Scott) |
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Att: 1
Exhibit A - 7/8/2021 Correspondence,
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Att: 2
Exhibit B - 8/23/2021 Service by Email Correspondence,
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Att: 3
Exhibit C - 8/23/2021 Service by WhatsApp Correspondence
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| Monday, August 16, 2021 | ||
| 10 | 10
service
Electronic Summons Reissued
Mon 08/16 3:45 PM
SUMMONS (2) Reissued Electronically as to REPUBLIC OF SOUTH SUDAN, SOUTH SUDAN MINISTRY OF DEFENCE AND VETERAN AFFAIRS. (ztth) |
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| Friday, August 13, 2021 | ||
| 9 | 9
cmp
Request for Summons to Issue
Fri 08/13 2:10 PM
REQUEST FOR SUMMONS TO ISSUE re1 Complaint,, filed by MARY ROE, JEANA GRAHAM, REBECCA CHOL NYGUNDENG, IRENE SCOTT, NATALIE CHANG, JANE DOE, GIAN LIBOT. Related document:1 Complaint,, filed by JANE DOE, GIAN LIBOT, IRENE SCOTT, JEANA GRAHAM, NATALIE CHANG, MARY ROE, REBECCA CHOL NYGUNDENG.(Gilmore, Scott) |
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| Thursday, July 15, 2021 | ||
| 8 | 8
misc
Redacted Document
Thu 07/15 4:48 PM
REDACTED DOCUMENT- Exhibit D to Complaint to Order on Motion for Miscellaneous Relief,1 Complaint,, by NATALIE CHANG, REBECCA CHOL NYGUNDENG, JANE DOE, JEANA GRAHAM, GIAN LIBOT, MARY ROE, IRENE SCOTT. (Gilmore, Scott) |
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| 7 | 7
motion
Miscellaneous Relief
Thu 07/15 11:39 AM
MOTION Seal Exhibit D to the Complaint and File Redacted Version re1 Complaint,, by NATALIE CHANG, REBECCA CHOL NYGUNDENG, JANE DOE, JEANA GRAHAM, GIAN LIBOT, MARY ROE, IRENE SCOTT.(Gilmore, Scott) |
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Att: 1
Exhibit 1 - Exhibit D to Complaint_redacted
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| 6 | 6
notice
Notice of Appearance
Thu 07/15 10:33 AM
NOTICE of Appearance by James Gotz on behalf of All Plaintiffs (Gotz, James) |
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order
Order on Motion for Miscellaneous Relief
Thu 07/15 4:39 PM
MINUTE ORDER granting7 Plaintiffs' Motion to File Document Under Seal: It is hereby ORDERED that the following document shall be placed under seal: Compl., Ex. D, ECF No. 1-4. It is FURTHER ORDERED that the Plaintiffs are granted leave to file the redacted version of that exhibit. See ECF No. 7-1. SO ORDERED. Signed by Judge Rudolph Contreras on 7/15/2021. (lcrc1) |
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notice
Notice of Corrected Docket Entry
Wed 09/08 10:55 AM
NOTICE OF CORRECTED DOCKET ENTRY: re6 Notice of Appearance was entered in error per counsel and counsel will refile said pleading with corrections. (ztd) |
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| Tuesday, July 13, 2021 | ||
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order
Order on Motion for Leave to Appear Pro Hac Vice
Tue 07/13 11:58 AM
MINUTE ORDER granting3 Motion for Leave to Appear Pro Hac Vice : Pursuant to Local Civil Rule 83.2, it is hereby ORDERED that James D. Gotz is admitted to represent Plaintiffs pro hac vice in this case. Counsel should register for e-filing via PACER and file a notice of appearance pursuant to Local Civil Rule 83.6(a). Click for instructions . SO ORDERED. Signed by Judge Rudolph Contreras on 7/13 /2021. (lcrc1) |
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| Monday, July 12, 2021 | ||
| 5 | 5
service
Electronic Summons Issued
Mon 07/12 3:45 PM
SUMMONS (2) Issued Electronically as to SOUTH SUDAN MINISTRY OF DEFENCE AND VETERAN AFFAIRS, THE REPUBLIC OF SOUTH SUDAN.(adh, ) |
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Att: 1
Notice and Consent
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utility
Case Assigned/Reassigned
Mon 07/12 3:39 PM
Case Assigned to Judge Rudolph Contreras. (adh, ) |
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| Friday, July 09, 2021 | ||
| 4 | 4
8
pgs
order
Order on Motion for Waiver
Mon 07/12 3:35 PM
ORDER granting2 Motion for Waiver of Local Civil Rules 5.1(c)(1) and 11.1 and for Leave to Proceed Anonymously is GRANTED, subject to any further consideration by the United States District Judge to whom this case is randomly assigned; it is further ORDERED that the case may proceed using the pseudonyms Jane Doe and Mary Roe for the plaintiffs who have requested to use pseudonyms; it is further ORDERED that the plaintiffs may substitute their residence addresses with the business address of their counsel; and it is further ORDERED that the plaintiffs residence addresses shall be filed with the Court ex parte and under seal. Signed by Chief Judge Beryl A. Howell on 7/9/2021. (adh, ) |
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| 3 | 3
motion
Appear Pro Hac Vice
Fri 07/09 3:26 PM
MOTION for Leave to Appear Pro Hac Vice :Attorney Name- James D. Gotz, Filing fee $ 100, receipt number ADCDC-8588767. Fee Status: Fee Paid. by NATALIE CHANG, REBECCA CHOL NYGUNDENG, JANE DOE, JEANA GRAHAM, GIAN LIBOT, MARY ROE, IRENE SCOTT.(Gilmore, Scott) |
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Att: 1
Exhibit A - Declaration of James Gotz in Support of Motion to Appear Pro Hac Vice,
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Att: 2
Exhibit B - Proposed Order Granting Motion to Appear Pro Hac Vice
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| Thursday, July 08, 2021 | ||
| 2 | 2
motion
Waiver
Thu 07/08 2:34 PM
Ex Parte MOTION for Waiver of Local Civil Rules 5.1(c)(1) and 11.1 and for Leave to Proceed Anonymously and Memorandum in Support Thereof by NATALIE CHANG, REBECCA CHOL NYGUNDENG, JANE DOE, JEANA GRAHAM, GIAN LIBOT, MARY ROE, IRENE SCOTT.(Gilmore, Scott) |
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Att: 1
Exhibit A,
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Att: 2
Exhibit B
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| 1 | 1
59
pgs
cmp
Complaint
Thu 07/08 2:13 PM
COMPLAINT against SOUTH SUDAN MINISTRY OF DEFENCE AND VETERAN AFFAIRS, THE REPUBLIC OF SOUTH SUDAN with Jury Demand ( Filing fee $ 402 receipt number ADCDC-8585013) filed by MARY ROE, JEANA GRAHAM, REBECCA CHOL NYGUNDENG, IRENE SCOTT, NATALIE CHANG, JANE DOE, GIAN LIBOT.(Gilmore, Scott) |
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Att: 1
Exhibit A,
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Att: 2
Exhibit B,
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Att: 3
Exhibit C,
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Att: 4
Exhibit D,
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Att: 5
Civil Cover Sheet,
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Att: 6
Summons The Republic of South Sudan,
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Att: 7
Summons South Sudan Ministry of Defence and Veteran Affairs
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