2:21-CV-12989
12/22/2021
Pending - Other Pending
Contract - Other Contract
Linda V. Parker
Curtis Ivy, Jr
RM AUCTIONS, INC.
RM CLASSIC CARS, INC.
KENNETH AHN
BROAD ARROW PRIVATE SALES, LLC d/b/a COLLECTORS GARAGE
Alain Squindo
Ian Kelleher
Michael Mortorano
Ruprecht Andrew (Barney)
Alexander Weaver
Ashley R. Fickel
Attorney at Dykema Gossett
333 S. Grand Ave., Suite 2100
Los Angeles, CA 90071
Mark J. Magyar
Attorney at Dykema Gossett PLLC
201 Townsend Street, Suite 900
Lansing, MI 48933
A. Michael Palizzi
Attorney at Miller, Canfield,
150 W. Jefferson Avenue, Suite 2500
Detroit, MI 48226-4415
Conor T. Fitzpatrick
Attorney at Miller Canfield Paddock & Stone, PLC
150 W Jefferson Avenue, Suite 2500
Detroit, MI 48226
Exhibit 1 (Madsen Declaration with Exhibits A and B)
Index of Exhibits Index
Exhibit K: Hagerty Events, LLC v. RM Auctions Inc. d/a/a RM Sothebys Verified Co
Exhibit J: February 25, 2022 Letter from Broad Arrow Employees Counsel to RM Cou
Exhibit H: RM Auctions, Inc. New York Workers Compensation Portal Information
Exhibit G: RM Auctions, Inc. 2015 Florida filing
Exhibit F: RM Auctions, Inc. 2000 Florida filing
Exhibit E: WANE.COM January 25, 2022 article
Exhibit B: 2021 RM Auctions, Inc. Indiana Foreign Business Registration
Exhibit A (signed return receipt)
(#4) CERTIFICATE OF SERVICE re #3 Summons Issued, #1 Complaint,, by RM AUCTIONS, INC., RM CLASSIC CARS, INC. (Attachments: #1 Exhibit A (signed return receipt)) (Magyar, Mark) (Entered: 01/13/2022)
(#2) SUMMONS Issued for *KENNETH AHN* (TTho) (Entered: 12/22/2021)
Exhibit 4
Exhibit 3
Exhibit 2
Exhibit 1
Index of Exhibits
(#4) CERTIFICATE OF SERVICE re #3 Summons Issued, #1 Complaint,, by RM AUCTIONS, INC., RM CLASSIC CARS, INC. (Attachments: #1 Exhibit A (signed return receipt)) (Magyar, Mark) (Entered: 01/13/2022)
Docket(#28) RESPONSE to #25 MOTION to Dismiss Amended Complaint and to Stay Amended Complaint in Favor of Arbitration filed by RM AUCTIONS, INC., RM CLASSIC CARS, INC.. (Attachments: #1 Index of Exhibits Index, #2 Exhibit 1 (Madsen Declaration with Exhibits A and B)) (Magyar, Mark) (Entered: 07/07/2022)
Docket(#27) STIPULATED ORDER REGARDING REMAINING BRIEFING SCHEDULE ON CERTAIN DEFENDANTS' MOTION TO DISMISS, Set Motion and R&R Deadlines/Hearings as to #25 MOTION to Dismiss Amended Complaint and to Stay Amended Complaint in Favor of Arbitration :( Response due by 7/7/2022, Reply due by 7/28/2022). Signed by District Judge Linda V. Parker. (AFla) (Entered: 06/07/2022)
Docket(#26) NOTICE by RM AUCTIONS, INC., RM CLASSIC CARS, INC. re #20 MOTION to Amend/Correct For Leave to File Second Amended Complaint, #22 Response to Motion (Magyar, Mark) (Entered: 05/23/2022)
Docket(#25) MOTION to Dismiss Amended Complaint and to Stay Amended Complaint in Favor of Arbitration by Ruprecht Andrew (Barney), Ian Kelleher, Michael Mortorano, Alain Squindo, Alexander Weaver. (Attachments: #1 Index of Exhibits, #2 Exhibit A: Alain Squindo Declaration, #3 Exhibit B: 2021 RM Auctions, Inc. Indiana Foreign Business Registration, #4 Exhibit C: RM Auctions, Inc. Indiana Property Warranty Deed, #5 Exhibit D: Fort Wayne Business Weekly January 25, 2022 article, #6 Exhibit E: WANE.COM January 25, 2022 article, #7 Exhibit F: RM Auctions, Inc. 2000 Florida filing, #8 Exhibit G: RM Auctions, Inc. 2015 Florida filing, #9 Exhibit H: RM Auctions, Inc. New York Workers Compensation Portal Information, #10 Exhibit I: AAA Commercial Arbitration Rule R-7(a), #11 Exhibit J: February 25, 2022 Letter from Broad Arrow Employees Counsel to RM Counsel, #12 Exhibit K: Hagerty Events, LLC v. RM Auctions Inc. d/a/a RM Sothebys Verified Complaint filed May 16, 2022 in the Delaware Court of Chancery) (Palizzi, A.) (Entered: 05/20/2022)
Docket(#24) STIPULATED ORDER REGARDING PAGE LIMITATIONS FOR BRIEFING ON BROAD ARROW EMPLOYEES' MOTION TO DISMISS AMENDED COMPLAINT Signed by District Judge Linda V. Parker. (AFla) (Entered: 05/20/2022)
Docket(#23) REPLY to Response re #15 MOTION to Dismiss First Amended Complaint - Corrected - In Support of Motion to Dismiss filed by KENNETH AHN. (Attachments: #1 Index of Exhibits, #2 Exhibit Declaration of A. Michael Palizzi) (Palizzi, A.) (Entered: 05/13/2022)
Docket(#22) RESPONSE to #20 MOTION to Amend/Correct For Leave to File Second Amended Complaint Opposing Plaintiff's Motion filed by KENNETH AHN. (Palizzi, A.) (Entered: 05/13/2022)
Docket(#21) [DOCUMENT IS TITLED REPLY BRIEF]RESPONSE to #15 MOTION to Dismiss First Amended Complaint in Support of Motion to Dismiss filed by KENNETH AHN. (Attachments: #1 Index of Exhibits, #2 Exhibit Declaration of A. Michael Palizzi) (Palizzi, A.) Modified on 5/13/2022 (DAll). (Entered: 05/13/2022)
Docket(#20) MOTION to Amend/Correct For Leave to File Second Amended Complaint by RM AUCTIONS, INC., RM CLASSIC CARS, INC.. (Attachments: #1 Index of Exhibits Exhibits 1 to 3, #2 Exhibit 1 (Magyar Declaration with Exhibits A through C), #3 Exhibit 2 (Proposed SAC, redline), #4 Exhibit 3 (Proposed SAC, clean)) (Magyar, Mark) (Entered: 04/29/2022)
Docket(#19) RESPONSE to #15 MOTION to Dismiss First Amended Complaint filed by RM AUCTIONS, INC., RM CLASSIC CARS, INC.. (Attachments: #1 Index of Exhibits Exhibits 1 Through 8, #2 Exhibit 1 (Magyar Declaration with Exhibits A through C), #3 Exhibit 2 (Delaware Emergency Motion 3.7.22), #4 Exhibit 3 (Delaware Order 3.8.22), #5 Exhibit 4 (Delaware Transcript, 3.11.22), #6 Exhibit 5 (Delaware Order, 3.11.22), #7 Exhibit 6 (Delaware Order, 3.17.22(, #8 Exhibit 7 (RM Motion to Dismiss Delaware case, 3.25.22), #9 Exhibit 8 (Delaware Order, 4.7.22)) (Magyar, Mark) (Entered: 04/29/2022)
Docket(#9) AMENDED COMPLAINT filed by RM AUCTIONS, INC., RM CLASSIC CARS, INC. against KENNETH AHN, Alain Squindo, Ian Kelleher, Michael Mortorano, Ruprecht Andrew (Barney), Alexander Weaver. NEW PARTIES ADDED. (Attachments: #1 Index of Exhibits Exhibits 1 through 13 to FAC, #2 Exhibit 1 (Ahn Employment Agreement), #3 Exhibit 2 (Ruprecht Employment Agreement), #4 Exhibit 3 (Weaver Employment Agreement), #5 Exhibit 4 (Squindo Employment Agreement), #6 Exhibit 5 (Kelleher Employment Agreement), #7 Exhibit 6 (Mortorano Employment Agreement), #8 Exhibit 7 (Ahn Amendment Agreement), #9 Exhibit 8 (Ahn Second Amendment Agreement), #10 Exhibit 9 (Mortorano Separation Agreement), #11 Exhibit 10 (Broad Arrow Press Release, 12.6.21), #12 Exhibit 11 (Broad Arrow Press Release, 12.13.21), #13 Exhibit 12 (Yahoo News Article, 12.13.21), #14 Exhibit 13 (Wayne County Business Court Complaint against BAG, Broad Arrow)) (Magyar, Mark) (Entered: 03/17/2022)
Docket(#8) MOTION to Dismiss by All Defendants. (Attachments: #1 Index of Exhibits, #2 Exhibit A, #3 Exhibit B, #4 Exhibit C, #5 Exhibit D, #6 Exhibit E, #7 Exhibit F) (Palizzi, A.) (Entered: 02/25/2022)
Docket(#7) STIPULATED ORDER FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT, ( Response due by 3/4/2022). Signed by District Judge Linda V. Parker. (AFla) (Entered: 01/20/2022)
Docket(#6) NOTICE of Appearance by A. Michael Palizzi on behalf of All Defendants. (Palizzi, A.) (Entered: 01/20/2022)
Docket(#5) NOTICE of Appearance by Conor T. Fitzpatrick on behalf of All Defendants. (Fitzpatrick, Conor) (Entered: 01/20/2022)
Docket(#4) CERTIFICATE OF SERVICE re #3 Summons Issued, #1 Complaint,, by RM AUCTIONS, INC., RM CLASSIC CARS, INC. (Attachments: #1 Exhibit A (signed return receipt)) (Magyar, Mark) (Entered: 01/13/2022)
DocketA United States Magistrate Judge of this Court is available to conduct all proceedings in this civil action in accordance with 28 U.S.C. 636c and FRCP 73. The Notice, Consent, and Reference of a Civil Action to a Magistrate Judge form is available for download at #http://www.mied.uscourts.gov (TTho) (Entered: 12/22/2021)
Docket(#3) SUMMONS Issued for *BROAD ARROW PRIVATE SALES, LLC d/b/a COLLECTORS GARAGE* (TTho) (Entered: 12/22/2021)
Docket(#2) SUMMONS Issued for *KENNETH AHN* (TTho) (Entered: 12/22/2021)
Docket(#1) COMPLAINT filed by All Plaintiffs against All Defendants. Plaintiff requests summons issued. Receipt No: AMIEDC-8732309 - Fee: $ 402. County of 1st Plaintiff: Out of state - County Where Action Arose: Wayne - County of 1st Defendant: Out of state. [Previously dismissed case: No] [Possible companion case(s): None] (Attachments: #1 Index of Exhibits, #2 Exhibit 1, #3 Exhibit 2, #4 Exhibit 3, #5 Exhibit 4) (Magyar, Mark) (Entered: 12/22/2021)
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