TRAFFIC PLANNING AND DESIGN, INC. v. WK2 LLC et al
| Pennsylvania Eastern District Court | |
| Judge: | Gerald A Mchugh |
| Case #: | 2:25-cv-00185 |
| 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: | Jan 10, 2025 |
| Last checked: Saturday Jan 11, 2025 2:31 AM EST |
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Defendant
DCS BACKUP
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Defendant
NICOLE KHAN
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Defendant
ADAM VOGEL
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Defendant
WK2 LLC
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Plaintiff
TRAFFIC PLANNING AND DESIGN, INC.
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Represented By
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SELECT A PARTY
PHILIP WURSTA
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| Docket last updated: 1 hours ago |
| Thursday, January 16, 2025 | ||
| 11 | 11
notice
Notice of Appearance
Thu 01/16 4:23 PM
NOTICE of Appearance by IMMON SHAFIEI on behalf of TRAFFIC PLANNING AND DESIGN, INC. with Certificate of Service(SHAFIEI, IMMON) |
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| 10 | 10
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pgs
order
Order on Motion to Expedite
Thu 01/16 2:28 PM
ORDER THAT PLAINTIFF'S4 MOTION FOR EXPEDITED DISCOVERY IS GRANTED IN PART AS FOLLOWS: 1. The Parties are permitted to serve written Requests for Production of Documents. Each Party upon whom a Request for Production of Documents is served shall fully and adequately respond within ten (10) days of receipt of the Requests for Production of Documents. 2. Plaintiff may conduct depositions of Nicole Khan and Philip Wursta. 3. In each deposition, the Parties may designate documents pursuant to Rule 34 that the individual deponent shall produce at or before the deposition. 4. Defendant Adam Vogel shall preserve and shall not alter all evidence that could be relevant to the resolution of this matter. 5. The Parties may notice the deposition to take place not less than five (5) business days from the date the notices of deposition are received by the deponent or counsel for the deponent. 6. The depositions must be conducted in person at a mutually agreeable site. SIGNED BY DISTRICT JUDGE GERALD A. MCHUGH ON 1/16/25.1/16/25 ENTERED AND COPIES MAILED AND E-MAILED.(fdc) |
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| Tuesday, January 14, 2025 | ||
| 9 | 9
notice
Notice of Appearance
Tue 01/14 4:42 PM
NOTICE of Appearance by BENJAMIN A. ANDERSEN on behalf of WK2 LLC, NICOLE KHAN, PHILIP WURSTA with Certificate of Service(ANDERSEN, BENJAMIN) |
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service
Waiver of Service Executed
Tue 01/14 11:45 AM
WAIVER OF SERVICE Returned Executed by TRAFFIC PLANNING AND DESIGN, INC.. PHILIP WURSTA waiver sent on 1/13/2025, answer due 3/14/2025. (PINKSTONE, WAYNE) |
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service
Waiver of Service Executed
Tue 01/14 11:43 AM
WAIVER OF SERVICE Returned Executed by TRAFFIC PLANNING AND DESIGN, INC.. NICOLE KHAN waiver sent on 1/13/2025, answer due 3/14/2025. (PINKSTONE, WAYNE) |
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| 6 | 6
service
Waiver of Service Executed
Tue 01/14 11:39 AM
WAIVER OF SERVICE Returned Executed by TRAFFIC PLANNING AND DESIGN, INC.. WK2 LLC waiver sent on 1/13/2025, answer due 3/14/2025. (PINKSTONE, WAYNE) |
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| Monday, January 13, 2025 | ||
| 5 | 5
service
Summons Issued
Mon 01/13 10:47 AM
Summons Issued as to DCS BACKUP, NICOLE KHAN, ADAM VOGEL, WK2 LLC, PHILIP WURSTA. Forwarded To: Wayne Pinkstone on 1/13/25 (fdc) |
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| Friday, January 10, 2025 | ||
| 4 | 4
motion
Expedite
Fri 01/10 9:36 PM
MOTION to Expedite Discovery filed by TRAFFIC PLANNING AND DESIGN, INC..Memorandum, Certificate of Service.(PINKSTONE, WAYNE) |
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Att: 1
Memorandum of Law in Support of Motion for Expedited Discovery,
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Att: 2
Exhibit A - Proposed Order,
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Att: 3
Certificate of Service
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| 3 | 3
motion
Temporary Restraining Order
Fri 01/10 9:23 PM
MOTION for Temporary Restraining Order and Preliminary Injunction filed by TRAFFIC PLANNING AND DESIGN, INC..Memorandum, Certificate of Service.(PINKSTONE, WAYNE) |
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Att: 1
Memorandum of Law in Support of Application for Temporary Restraining Order,
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Att: 2
Text of Proposed Order,
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Att: 3
Certificate of Service
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discov
Disclosure Statement Form 7.1
Fri 01/10 8:57 PM
Disclosure Statement Form pursuant to FRCP 7.1 with Certificate of Service by TRAFFIC PLANNING AND DESIGN, INC..(PINKSTONE, WAYNE) |
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Att: 1
Certificate of Service
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33
pgs
cmp
Complaint (Attorney)
Fri 01/10 8:52 PM
COMPLAINT against DCS BACKUP, NICOLE KHAN, ADAM VOGEL, WK2 LLC, PHILIP WURSTA ( Filing fee $ 405 receipt number APAEDC-17994610.), filed by TRAFFIC PLANNING AND DESIGN, INC..(PINKSTONE, WAYNE) |
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Att: 1
Exhibit A - Employee Handbook,
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Att: 2
Exhibit B - Handbook Acknowledgments by Khan and Wursta,
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Att: 3
Exhibit C - 12.10.24 Cease and Desist Letter to Khan,
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Att: 4
Exhibit D - 12.19.24 Khan Letter Response to Cease and Desist,
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Att: 5
Exhibit E - 12.23.24 Reply Letter to Khan,
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Att: 6
Exhibit F - 12.23.24 Cease and Desis Letter to Wursta,
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Att: 7
Exhibit G - 12.27.24 Khan Letter Response to 12.23 Reply,
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Att: 8
Exhibit H - January 2025 Email Thread,
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Att: 9
Exhibit I - 01.10.24 Khan Letter,
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Att: 10
Exhibit J - 01.10.24 Wursta Letter Response to Cease and Desist,
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Att: 11
Civil Cover Sheet,
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Att: 12
Designation Form,
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Att: 13
Certificate of Service
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