Your recipients will receive an email with this envelope shortly and will be able to access it on trellis. You can always see your envelopes by clicking the Inbox on the top right hand corner.
The Reliable Automatic Sprinkler Co. Inc v. Jtmm Enterprises Inc., John Plut And, Samuel F. Cooper
A Commercial Division case was filed by (Subcribe to view) represented by (Subcribe to view) against (Subscribe to view) represented by (Subscribe to view) in the jurisdiction of Westchester County. Judge Linda S Jamieson presiding.
Case Details
Case Number
Filing Date
March 24, 2021
Last Refreshed
July 26, 2023
Filing Location
Westchester County, NY
OTHER JUDGES ON THIS CASE
Linda A;Category
Commercial Division
Practice Area
Commercial
Matter Type
General Commercial
Status
Appealed
OTHER JUDGES ON THIS CASE
Overview
This is an action to recover damages in connection with Defendants’ fraud,
conspiracy and multiple flagrant breaches of fiduciary duties owed to Plaintiff. Upon information
and belief, between August 2019 and February 2021, Cooper, one of Plaintiff’s former employees,
developed, engaged in, and conspired with JTMM and Plut in an illicitinformation technology
(“IT”) services scheme wherein Reliable was, inter alia, overcharged for IT products, services and
support. Through his connections with Plut and Plut’s shell company, JTMM, Cooper (with help
from JTMM and Plut) used his position as Senior Project Manager at Reliable to induce Reliable to
enter into an Independent Contractor Agreement, dated January 24, 2020 (the “Contract”) with
JTMM and overcharge and defraud Plaintiff in excess of $650,000 for IT consulting staff and
support services purportedly supplied by JTMM to Reliable over a one-year period. As a
Causes of Action
1. Breach of Contract Against JTMM
2. Fraud Against JTMM, Plut, and Cooper
3. Fraud in the Inducement Against JTMM, Plut, and Cooper
4. Faithless Servant Against Cooper
5. Tortious Interference Against Plut and JTMM
6. Conspiracy Against JTMM, Plut and Cooper
7. Aiding and Abetting Fraud Against Cooper and Plut
Parties
Plaintiffs
The Reliable Automatic Sprinkler Co. Inc
Attorneys for Plaintiffs
Guerrero, Rosa Guadalupe
Leone, Amanda Marie
Mahalli, Solmaz Orly
Stallone, Maryann C
Syracuse, Vincent J
Defendants
John Plut And
Jtmm Enterprises Inc.
Samuel F. Cooper
Attorneys for Defendants
Davis, Lauren Rayner
O'Connor, Kevin J
Case Documents
NOTICE OF APPEAL/INFORMATIONAL STATEMENT/COPY OF ORDER/PROOF OF SERVICE
Date: May 19, 2023
NOTICE OF APPEARANCE (PRE RJI)
Date: May 19, 2023
STIPULATION OF DISCONTINUANCE - SO ORDERED
Date: May 02, 2023
MEMORANDUM
Date: Apr 25, 2023
AFFIRMATION/AFFIDAVIT OF SERVICE
Date: Apr 24, 2023
NOTICE OF ENTRY
Date: Apr 21, 2023
DECISION ORDER ON MOTION
Date: Apr 21, 2023
EXHIBIT(S) - 1 (Motion 7)
Date: Apr 10, 2023
EXHIBIT(S) - 1 (Motion 7)
Date: Apr 05, 2023
EXHIBIT(S) - 4 (Motion 7)
Date: Apr 05, 2023
EXHIBIT(S) - 3 (Motion 7)
Date: Apr 05, 2023
EXHIBIT(S) - 6 (Motion 7)
Date: Apr 05, 2023
EXHIBIT(S) - 7 (Motion 7)
Date: Apr 05, 2023
EXHIBIT(S) - 2 (Motion 7)
Date: Apr 05, 2023
EXHIBIT(S) - 8 (Motion 7)
Date: Apr 05, 2023
NOTICE OF REJECTION
Date: Apr 05, 2023
EXHIBIT(S) - 1 (Motion 7)
Date: Apr 05, 2023
EXHIBIT(S) - 9 (Motion 7)
Date: Apr 05, 2023
AFFIDAVIT OR AFFIRMATION IN SUPPORT OF MOTION
Date: Apr 05, 2023
EXHIBIT(S) - I (Motion 9)
Date: Apr 03, 2023
NOTICE OF CROSS-MOTION
Date: Apr 03, 2023
EXHIBIT(S) - B (Motion 9)
Date: Apr 03, 2023
EXHIBIT(S) - A (Motion 9)
Date: Apr 03, 2023
EXHIBIT(S) - D (Motion 9)
Date: Apr 03, 2023
EXHIBIT(S) - E (Motion 9)
Date: Apr 03, 2023
EXHIBIT(S) - C (Motion 9)
Date: Apr 03, 2023
EXHIBIT(S) - F (Motion 9)
Date: Apr 03, 2023
EXHIBIT(S) - P (Motion 9)
Date: Apr 03, 2023
EXHIBIT(S) - O (Motion 9)
Date: Apr 03, 2023
EXHIBIT(S) - N (Motion 9)
Date: Apr 03, 2023
AFFIDAVIT (Motion 9)
Date: Apr 03, 2023
EXHIBIT(S) - M (Motion 9)
Date: Apr 03, 2023
EXHIBIT(S) - R (Motion 9)
Date: Apr 03, 2023
EXHIBIT(S) - S (Motion 9)
Date: Apr 03, 2023
EXHIBIT(S) - T (Motion 9)
Date: Apr 03, 2023
EXHIBIT(S) - L (Motion 9)
Date: Apr 03, 2023
EXHIBIT(S) - J (Motion 9) Bankruptcy Filing
Date: Apr 03, 2023
EXHIBIT(S) - K (Motion 9)
Date: Apr 03, 2023
EXHIBIT(S) - H (Motion 9)
Date: Apr 03, 2023
EXHIBIT(S) - G (Motion 9)
Date: Apr 03, 2023
EXHIBIT(S) - 1 (Motion 8)
Date: Apr 03, 2023
MEMORANDUM IN OPPOSITION TO MOTION AND IN SUPPORT OF CROSS-MOTION (Motion 9)
Date: Apr 03, 2023
EXHIBIT(S) - Q (Motion 9)
Date: Apr 03, 2023
EXHIBIT(S) - 2 (Motion 8)
Date: Apr 03, 2023
AFFIDAVIT OR AFFIRMATION IN OPPOSITION TO MOTION
Date: Apr 03, 2023
NOTICE OF MOTION
Date: Mar 30, 2023
STIPULATION - DISCONTINUANCE ( REQUEST TO SO ORDER )
Date: Mar 16, 2023
LETTER / CORRESPONDENCE TO JUDGE
Date: Mar 13, 2023
NOTICE OF MOTION (Motion 7) Corrected
Date: Mar 09, 2023
EXHIBIT(S) - C (Motion 7)
Date: Mar 09, 2023
EXHIBIT(S) - D (Motion 7)
Date: Mar 09, 2023
EXHIBIT(S) - B (Motion 7)
Date: Mar 09, 2023
EXHIBIT(S) - A (Motion 7)
Date: Mar 09, 2023
EXHIBIT(S) - E (Motion 7)
Date: Mar 09, 2023
LETTER / CORRESPONDENCE TO JUDGE
Date: Feb 13, 2023
NOTE OF ISSUE:WITH JURY
Date: Feb 07, 2023
LETTER / CORRESPONDENCE TO JUDGE
Date: Jan 04, 2023
COURT NOTICE
Date: Dec 13, 2022
LETTER / CORRESPONDENCE TO JUDGE
Date: Dec 09, 2022
LETTER / CORRESPONDENCE TO JUDGE
Date: Nov 17, 2022
LETTER / CORRESPONDENCE TO JUDGE
Date: Nov 07, 2022
LETTER / CORRESPONDENCE TO JUDGE
Date: Nov 01, 2022
LETTER / CORRESPONDENCE TO JUDGE
Date: Oct 31, 2022
DECISION ORDER ON MOTION
Date: Sep 21, 2022
NOTICE OF ENTRY (Motion 6)
Date: Sep 21, 2022
LETTER / CORRESPONDENCE TO JUDGE
Date: Sep 09, 2022
RESPONSE TO DEMAND
Date: Sep 02, 2022
COURT NOTICE
Date: Aug 26, 2022
STIPULATION - SO ORDERED
Date: Aug 19, 2022
AFFIRMATION/AFFIDAVIT OF SERVICE
Date: Aug 18, 2022
STIPULATION - CONFIDENTIALITY ( REQUEST TO SO ORDER )
Date: Aug 08, 2022
LETTER / CORRESPONDENCE TO JUDGE
Date: Aug 08, 2022
EXHIBIT(S) - 7 (Motion 6)
Date: Jul 19, 2022
NOTICE OF CROSS-MOTION (Motion 6)
Date: Jul 19, 2022
EXHIBIT(S) - 1 (Motion 6)
Date: Jul 19, 2022
EXHIBIT(S) - 2 (Motion 6)
Date: Jul 19, 2022
EXHIBIT(S) - 4 (Motion 6)
Date: Jul 19, 2022
EXHIBIT(S) - 8 (Motion 6)
Date: Jul 19, 2022
EXHIBIT(S) - 3 (Motion 6)
Date: Jul 19, 2022
EXHIBIT(S) - 1 (Motion 6)
Date: Jul 19, 2022
EXHIBIT(S) - 6 (Motion 6)
Date: Jul 19, 2022
EXHIBIT(S) - 2 (Motion 6)
Date: Jul 19, 2022
EXHIBIT(S) - 5 (Motion 6)
Date: Jul 19, 2022
AFFIDAVIT OR AFFIRMATION IN SUPPORT OF CROSS-MOTION (Motion 6)
Date: Jul 19, 2022
EXHIBIT(S) - 9 (Motion 6)
Date: Jul 19, 2022
EXHIBIT(S) - 3 (Motion 6)
Date: Jul 19, 2022
AFFIDAVIT OR AFFIRMATION IN SUPPORT OF CROSS-MOTION (Motion 6)
Date: Jul 19, 2022
LETTER / CORRESPONDENCE TO JUDGE
Date: Jul 05, 2022
LETTER / CORRESPONDENCE TO JUDGE
Date: Jul 01, 2022
ORDER - PRELIMINARY CONFERENCE
Date: Jun 30, 2022
EXHIBIT(S) - 6 (Motion 5)
Date: Jun 28, 2022
NOTICE OF MOTION (Motion 5) Corrected
Date: Jun 28, 2022
EXHIBIT(S) - 4 (Motion 5)
Date: Jun 28, 2022
EXHIBIT(S) - 1 (Motion 5)
Date: Jun 28, 2022
EXHIBIT(S) - 3 (Motion 5)
Date: Jun 28, 2022
EXHIBIT(S) - 7 (Motion 5)
Date: Jun 28, 2022
EXHIBIT(S) - 2 (Motion 5)
Date: Jun 28, 2022
EXHIBIT(S) - 5 (Motion 5)
Date: Jun 28, 2022
AFFIDAVIT (Motion 5)
Date: Jun 28, 2022
AFFIRMATION/AFFIDAVIT OF SERVICE
Date: Jun 15, 2022
ANSWER
Date: Jun 13, 2022
DECISION ORDER ON MOTION
Date: Jun 03, 2022
NOTICE OF ENTRY
Date: Jun 03, 2022
LETTER / CORRESPONDENCE TO JUDGE
Date: May 19, 2022
LETTER / CORRESPONDENCE TO JUDGE
Date: May 17, 2022
NOTICE OF APPEARANCE (POST RJI)
Date: May 16, 2022
ORDER - PRELIMINARY CONFERENCE
Date: Apr 04, 2022
STIPULATION - CONFIDENTIALITY
Date: Mar 16, 2022
PRELIMINARY CONFERENCE ORDER (PROPOSED)
Date: Mar 16, 2022
STIPULATION - OTHER - ( REQUEST TO SO ORDER )
Date: Mar 10, 2022
NOTICE OF BANKRUPTCY (PRE RJI)
Date: Mar 03, 2022
ADJOURNMENT OF CONFERENCE -REQUEST
Date: Jan 19, 2022
EXHIBIT(S) - 2 (Motion 4)
Date: Dec 30, 2021
AFFIDAVIT OR AFFIRMATION IN SUPPORT OF CROSS-MOTION (Motion 4)
Date: Dec 30, 2021
EXHIBIT(S) - 1 (Motion 4)
Date: Dec 30, 2021
EXHIBIT(S) - 3 (Motion 4)
Date: Dec 30, 2021
EXHIBIT(S) - 4 (Motion 4)
Date: Dec 30, 2021
EXHIBIT(S) - 5 (Motion 4)
Date: Dec 30, 2021
EXHIBIT(S) - 3 (Motion 4)
Date: Dec 30, 2021
AFFIDAVIT OR AFFIRMATION IN SUPPORT (Motion 4)
Date: Dec 30, 2021
EXHIBIT(S) - 7 (Motion 4)
Date: Dec 30, 2021
EXHIBIT(S) - 1 (Motion 4)
Date: Dec 30, 2021
EXHIBIT(S) - 8 (Motion 4)
Date: Dec 30, 2021
EXHIBIT(S) - 6 (Motion 4)
Date: Dec 30, 2021
EXHIBIT(S) - 2 (Motion 4)
Date: Dec 30, 2021
NOTICE OF CROSS-MOTION (Motion 4)
Date: Dec 30, 2021
MEMORANDUM OF LAW IN REPLY (Motion 2)
Date: Dec 20, 2021
NOTICE OF REJECTION
Date: Dec 10, 2021
EXHIBIT(S) - 1 (Motion 2)
Date: Dec 09, 2021
EXHIBIT(S) - 2 (Motion 2)
Date: Dec 09, 2021
MEMORANDUM OF LAW IN OPPOSITION (Motion 2)
Date: Dec 09, 2021
AFFIDAVIT OR AFFIRMATION IN OPPOSITION TO MOTION (Motion 2)
Date: Dec 09, 2021
NOTICE OF MOTION (Motion 3)
Date: Dec 09, 2021
EXHIBIT(S) - 3 (Motion 2)
Date: Dec 09, 2021
ORDER - PRELIMINARY CONFERENCE
Date: Nov 17, 2021
EXHIBIT(S) - B (Motion 2)
Date: Nov 09, 2021
MEMORANDUM OF LAW IN SUPPORT
Date: Nov 09, 2021
NOTICE OF MOTION (Motion 2) Corrected
Date: Nov 09, 2021
EXHIBIT(S) - A (Motion 2)
Date: Nov 09, 2021
AFFIDAVIT OR AFFIRMATION IN SUPPORT OF MOTION
Date: Nov 09, 2021
EXHIBIT(S) - C (Motion 2)
Date: Nov 09, 2021
EXHIBIT(S) - D (Motion 2)
Date: Nov 09, 2021
LETTER / CORRESPONDENCE TO JUDGE
Date: Nov 05, 2021
REPLY TO COUNTERCLAIM(S)
Date: Oct 06, 2021
LETTER / CORRESPONDENCE TO JUDGE
Date: Oct 05, 2021
NOTICE OF APPEARANCE (POST RJI)
Date: Sep 20, 2021
ANSWER WITH COUNTER-CLAIM(S)
Date: Sep 16, 2021
LETTER / CORRESPONDENCE TO JUDGE
Date: Sep 16, 2021
EXHIBIT(S) - 2
Date: Aug 27, 2021
EXHIBIT(S) - 1
Date: Aug 27, 2021
EXHIBIT(S) - 8
Date: Aug 27, 2021
EXHIBIT(S) - 7
Date: Aug 27, 2021
EXHIBIT(S) - 3
Date: Aug 27, 2021
EXHIBIT(S) - 5
Date: Aug 27, 2021
EXHIBIT(S) - 9
Date: Aug 27, 2021
COMPLAINT (AMENDED)
Date: Aug 27, 2021
EXHIBIT(S) - 4
Date: Aug 27, 2021
EXHIBIT(S) - 6
Date: Aug 27, 2021
STIPULATION - TIME TO ANSWER
Date: Aug 11, 2021
DECISION ORDER ON MOTION
Date: Aug 11, 2021
NOTICE OF APPEARANCE (POST RJI)
Date: Aug 09, 2021
NOTICE OF APPEARANCE (POST RJI)
Date: Aug 09, 2021
PRELIMINARY CONFERENCE ORDER (PROPOSED)
Date: Aug 02, 2021
LETTER / CORRESPONDENCE TO JUDGE
Date: Jul 27, 2021
STIPULATION - TIME TO ANSWER
Date: Jul 21, 2021
AFFIRMATION/AFFIDAVIT OF SERVICE
Date: Jul 06, 2021
NOTICE OF APPEARANCE (POST RJI)
Date: Jul 01, 2021
ORDER ( PROPOSED )
Date: Jun 30, 2021
NOTICE OF APPEARANCE (POST RJI)
Date: Jun 30, 2021
NOTICE OF MOTION (Motion 1)
Date: Jun 30, 2021
AFFIDAVIT OR AFFIRMATION IN SUPPORT (Motion 1)
Date: Jun 30, 2021
COMPLAINT
Date: Jun 28, 2021
LETTER/CORRESPONDENCE FROM COURT
Date: Jun 17, 2021
RJI -RE: REQUEST FOR PRELIMINARY CONFERENCE
Date: Jun 17, 2021
ADDENDUM - COMMERCIAL DIVISION (840C)
Date: Jun 17, 2021
AFFIRMATION/AFFIDAVIT OF SERVICE
Date: Jun 02, 2021
AFFIRMATION/AFFIDAVIT OF SERVICE
Date: May 25, 2021
AFFIRMATION/AFFIDAVIT OF SERVICE
Date: May 25, 2021
AFFIRMATION/AFFIDAVIT OF SERVICE
Date: May 25, 2021
SUMMONS WITH NOTICE
Date: Mar 24, 2021Case Events
| Date | Type | Description | |
|---|---|---|---|
| May 19, 2023 | NOTICE OF APPEAL/INFORMATIONAL STATEMENT/COPY OF ORDER/PROOF OF SERVICE | ||
| May 19, 2023 |
NOTICE OF APPEARANCE (PRE RJI) Notice of Appearance of Kevin J. O'Connor on behalf of Defendant Samuel F. Cooper |
||
| May 02, 2023 | STIPULATION OF DISCONTINUANCE - SO ORDERED | ||
| April 25, 2023 | MEMORANDUM | ||
| April 24, 2023 |
AFFIRMATION/AFFIDAVIT OF SERVICE Affidavit of Service of Notice Of Entry Motion 7, 8, 9 |
||
| April 21, 2023 | NOTICE OF ENTRY | ||
| April 21, 2023 | DECISION + ORDER ON MOTION | ||
| April 10, 2023 |
EXHIBIT(S) - 1 (Motion #7) filing corrected Bankruptcy document |
||
| April 05, 2023 |
EXHIBIT(S) - 1 (Motion #7) Notice of Bankruptcy filing for representation |
||
| April 05, 2023 |
EXHIBIT(S) - 4 (Motion #7) PLUT testimony |
||
| April 05, 2023 |
EXHIBIT(S) - 3 (Motion #7) FJ FEE Sworn transcript |
||
| April 05, 2023 |
EXHIBIT(S) - 6 (Motion #7) manual cooper signed Liberty SC employee |
||
| April 05, 2023 |
EXHIBIT(S) - 7 (Motion #7) Sam Cooper Signed agreement SC Employee highlighted |
||
| April 05, 2023 |
EXHIBIT(S) - 2 (Motion #7) JTMMM and plut dismissal |
||
| April 05, 2023 |
EXHIBIT(S) - 8 (Motion #7) Steve Wolin testimony |
||
| April 05, 2023 | Notice of Rejection with Exhibits. | ||
| April 05, 2023 |
EXHIBIT(S) - 1 (Motion #7) notice to Bankruptcy court |
||
| April 05, 2023 |
EXHIBIT(S) - 9 (Motion #7) JTMM Counsel to Syracuse |
||
| April 05, 2023 | AFFIDAVIT OR AFFIRMATION IN SUPPORT OF MOTION | ||
| April 03, 2023 | AFFIDAVIT OR AFFIRMATION IN OPPOSITION TO MOTION AND IN SUPPORT OF CROSS-MOTION | ||
| April 03, 2023 |
EXHIBIT(S) - I (Motion #9) Plaintiff's Opp and Cross |
||
| April 03, 2023 | NOTICE OF CROSS-MOTION | ||
| April 03, 2023 |
EXHIBIT(S) - B (Motion #9) Service of Summons |
||
| April 03, 2023 |
EXHIBIT(S) - A (Motion #9) Summons |
||
| April 03, 2023 |
EXHIBIT(S) - D (Motion #9) Service of Complaint |
||
| April 03, 2023 |
EXHIBIT(S) - E (Motion #9) Bankruptcy Letter |
||
| April 03, 2023 |
EXHIBIT(S) - C (Motion #9) Complaint |
||
| April 03, 2023 |
EXHIBIT(S) - F (Motion #9) Amended Complaint |
||
| April 03, 2023 |
EXHIBIT(S) - P (Motion #9) Notice of Entry of Sept 21 Order |
||
| April 03, 2023 |
EXHIBIT(S) - O (Motion #9) Sept 21 Order |
||
| April 03, 2023 |
EXHIBIT(S) - N (Motion #9) Plaintiff's Opp and Cross 2 |
||
| April 03, 2023 |
AFFIDAVIT (Motion #9) Wolin Affidavit |
||
| April 03, 2023 |
EXHIBIT(S) - M (Motion #9) Notice of Motion to Remove |
||
| April 03, 2023 |
EXHIBIT(S) - R (Motion #9) Motion to Vacate Default Judgment |
||
| April 03, 2023 |
EXHIBIT(S) - S (Motion #9) Stip of Discon as to JTMM only |
||
| April 03, 2023 |
EXHIBIT(S) - T (Motion #9) Motion for Continuance |
||
| April 03, 2023 |
EXHIBIT(S) - L (Motion #9) Notice of Entry on June 3, Order |
||
| April 03, 2023 |
EXHIBIT(S) - J (Motion #9) Bankruptcy Filing Bankruptcy Filing Possible SSN Administratively Redacted |
||
| April 03, 2023 |
EXHIBIT(S) - K (Motion #9) June 3, Order |
||
| April 03, 2023 |
EXHIBIT(S) - H (Motion #9) Envelope and Notice of Motion |
||
| April 03, 2023 |
EXHIBIT(S) - G (Motion #9) Bankruptcy Order |
||
| April 03, 2023 |
EXHIBIT(S) - 1 (Motion #8) Bankruptcy Order |
||
| April 03, 2023 |
MEMORANDUM IN OPPOSITION TO MOTION AND IN SUPPORT OF CROSS-MOTION (Motion #9) MOL in Opp and in Support of Cross Motion |
||
| April 03, 2023 |
EXHIBIT(S) - Q (Motion #9) NOI |
||
| April 03, 2023 |
EXHIBIT(S) - 2 (Motion #8) Bankruptcy Petition and Plan |
||
| April 03, 2023 | AFFIDAVIT OR AFFIRMATION IN OPPOSITION TO MOTION | ||
| March 30, 2023 | NOTICE OF MOTION | ||
| March 16, 2023 | STIPULATION - DISCONTINUANCE ( REQUEST TO SO ORDER ) | ||
| March 13, 2023 | LETTER / CORRESPONDENCE TO JUDGE | ||
| March 09, 2023 |
NOTICE OF MOTION (Motion #7) *Corrected* To Vacate Judgement with Support |
||
| March 09, 2023 |
EXHIBIT(S) - C (Motion #7) Deposition of FJ FEE |
||
| March 09, 2023 |
EXHIBIT(S) - D (Motion #7) Deposition of Steve Wolin |
||
| March 09, 2023 |
EXHIBIT(S) - B (Motion #7) Answer, Affirmative Defenses and Counterclim |
||
| March 09, 2023 |
EXHIBIT(S) - A (Motion #7) Samuel F Cooper AFF in support |
||
| March 09, 2023 |
EXHIBIT(S) - E (Motion #7) Letter JTMM counsel |
||
| February 13, 2023 | LETTER / CORRESPONDENCE TO JUDGE | ||
| February 07, 2023 | NOTE OF ISSUE:WITH JURY | ||
| January 04, 2023 | LETTER / CORRESPONDENCE TO JUDGE | ||
| December 13, 2022 | COURT NOTICE | ||
| December 09, 2022 | LETTER / CORRESPONDENCE TO JUDGE | ||
| November 17, 2022 | LETTER / CORRESPONDENCE TO JUDGE | ||
| November 07, 2022 | LETTER / CORRESPONDENCE TO JUDGE | ||
| November 01, 2022 |
LETTER / CORRESPONDENCE TO JUDGE Letter to the Judge |
||
| October 31, 2022 |
LETTER / CORRESPONDENCE TO JUDGE Seek leave to bring a motion to compel |
||
| September 21, 2022 | DECISION + ORDER ON MOTION | ||
| September 21, 2022 |
NOTICE OF ENTRY (Motion #6) Notice of Entry with Affidavit of Service |
||
| September 09, 2022 | LETTER / CORRESPONDENCE TO JUDGE | ||
| September 02, 2022 | RESPONSE TO DEMAND | ||
| August 26, 2022 | COURT NOTICE | ||
| August 19, 2022 |
STIPULATION - SO ORDERED Confidentiality |
||
| August 18, 2022 |
AFFIRMATION/AFFIDAVIT OF SERVICE Affidavit of Service upon Berkley Insurance Company |
||
| August 08, 2022 |
STIPULATION - CONFIDENTIALITY ( REQUEST TO SO ORDER ) Amended Stipulation and Order for the Production and Exchange of Confidential Information |
||
| August 08, 2022 |
LETTER / CORRESPONDENCE TO JUDGE Letter to Judge Jamieson re: Request to so order Stipulation and Order |
||
| July 19, 2022 |
MEMORANDUM IN OPPOSITION TO MOTION AND IN SUPPORT OF CROSS-MOTION (Motion #6) PLAINTIFF'S MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANT SAMUEL F. COOPER'S MOTION TO TRANSFER THIS PLAINTIFF'S MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANT SAMUEL F. COOPER'S MOTION TO TRANSFER THIS ... show more |
||
| July 19, 2022 |
EXHIBIT(S) - 7 (Motion #6) AFFIRMATION OF VINCENT J. SYRACUSE EX. 7 - BANKRUPTCY COURT ORDER |
||
| July 19, 2022 |
NOTICE OF CROSS-MOTION (Motion #6) NOTICE OF CROSS-MOTION |
||
| July 19, 2022 |
EXHIBIT(S) - 1 (Motion #6) AFFIRMATION OF VINCENT J. SYRACUSE EX. 1 - SUMMONS WITH NOTICE |
||
| July 19, 2022 |
EXHIBIT(S) - 2 (Motion #6) AFFIRMATION OF VINCENT J. SYRACUSE EX. 2 - PLAINTIFFS AFFIDAVIT OF SERVICE |
||
| July 19, 2022 |
EXHIBIT(S) - 4 (Motion #6) AFFIRMATION OF VINCENT J. SYRACUSE EX. 4 - PLAINTIFFS VERIFIED COMPLAINT |
||
| July 19, 2022 |
EXHIBIT(S) - 8 (Motion #6) AFFIRMATION OF VINCENT J. SYRACUSE EX. 8 - COOPER MAILING ENVELOPE |
||
| July 19, 2022 |
EXHIBIT(S) - 3 (Motion #6) AFFIRMATION OF VINCENT J. SYRACUSE EX. 3 - PLAINTIFFS AFFIDAVIT OF ADDITIONAL MAILING |
||
| July 19, 2022 |
EXHIBIT(S) - 1 (Motion #6) AFFIDAVIT OF STEVEN WOLIN EX. 1 - COOPER PAYSTUB REDACTED |
||
| July 19, 2022 |
EXHIBIT(S) - 6 (Motion #6) AFFIRMATION OF VINCENT J. SYRACUSE EX. 6 - PLAINTIFFS AMENDED VERIFIED COMPLAINT (WITH EXHIBITS 1-9) |
||
| July 19, 2022 |
EXHIBIT(S) - 2 (Motion #6) AFFIDAVIT OF STEVEN WOLIN EX. 2 - PROPOSED AGREEMENT |
||
| July 19, 2022 |
EXHIBIT(S) - 5 (Motion #6) AFFIRMATION OF VINCENT J. SYRACUSE EX. 5 - COOPERS BANKRUPTCY LETTER TO THE COURT |
||
| July 19, 2022 |
AFFIDAVIT OR AFFIRMATION IN SUPPORT OF CROSS-MOTION (Motion #6) AFFIDAVIT OF STEVEN WOLIN IN SUPPORT OF CROSS-MOTION |
||
| July 19, 2022 |
EXHIBIT(S) - 9 (Motion #6) AFFIRMATION OF VINCENT J. SYRACUSE EX. 9 - EMAIL CORRESPONDENCE WITH ALL PARTIES |
||
| July 19, 2022 |
EXHIBIT(S) - 3 (Motion #6) AFFIDAVIT OF STEVEN WOLIN EX. 3 - LETTER WITHDRAWING AGREEMENT |
||
| July 19, 2022 |
AFFIDAVIT OR AFFIRMATION IN SUPPORT OF CROSS-MOTION (Motion #6) AFFIRMATION OF VINCENT J. SYRACUSE |
||
| July 05, 2022 |
LETTER / CORRESPONDENCE TO JUDGE Letter to Court in response to letter filed by Plaintiff |
||
| July 01, 2022 |
LETTER / CORRESPONDENCE TO JUDGE Letter Application for a Court Conference |
||
| June 30, 2022 |
ORDER - PRELIMINARY CONFERENCE AMENDED |
||
| June 28, 2022 |
EXHIBIT(S) - 6 (Motion #5) LIBERTY EMPLOYEE MANUEL SIGNED SAMUEL F COOPER |
||
| June 28, 2022 |
NOTICE OF MOTION (Motion #5) *Corrected* NOTICE OF MOTION TRANSFER TO FEDERAL COURT |
||
| June 28, 2022 |
EXHIBIT(S) - 4 (Motion #5) US BANKRUPTCY ORDER SAMUEL FRANK COOPER |
||
| June 28, 2022 |
EXHIBIT(S) - 1 (Motion #5) SWORN AFFIDAVIT PROSE SAMUEL F COOPER DEC 9TH 2021 |
||
| June 28, 2022 |
EXHIBIT(S) - 3 (Motion #5) LETTER TO OPPOSING COUNCIL BANKRUPTCY JULY 21 2021 NOTARIZED |
||
| June 28, 2022 |
EXHIBIT(S) - 7 (Motion #5) GENERAL RELEASE AGREEMENT INTENT FOR VENUE |
||
| June 28, 2022 |
EXHIBIT(S) - 2 (Motion #5) SERVICE TO OPPOSING COUNCIL ON DEC 9TH 2021 |
||
| June 28, 2022 |
EXHIBIT(S) - 5 (Motion #5) KEY EMPLOYEE AGREEMENT SIGNED SAMUEL F COOPER RELIABLE SPRINKLER |
||
| June 28, 2022 |
AFFIDAVIT (Motion #5) AFFIVDAVIT OF SAMUEL F COOPER IN SUPPORT OF MOTION |
||
| June 24, 2022 |
PRELIMINARY CONFERENCE ORDER (PROPOSED) LETTER DATED JUNE 24, 2022 TO JUDGE LINDA S\. JAMIESON REQUESTING THAT THE AMENDED PRELIMINARY CONFER LETTER DATED JUNE 24, 2022 TO JUDGE LINDA S\. JAMIESON REQUESTING THAT THE AMENDED PRELIMINARY CONFER ... show more 
|
||
| June 15, 2022 | AFFIRMATION/AFFIDAVIT OF SERVICE | ||
| June 13, 2022 |
ANSWER Defendant John Plut's Verified Answer and Affirmative Defenses |
||
| June 03, 2022 | DECISION + ORDER ON MOTION | ||
| June 03, 2022 | NOTICE OF ENTRY | ||
| May 19, 2022 |
LETTER / CORRESPONDENCE TO JUDGE Ltr to Court in response to the 5/17/2022 letter filed by Plaintiff re: Pre-Motion Conf Req |
||
| May 17, 2022 |
LETTER / CORRESPONDENCE TO JUDGE Letter to Court RE: May 19, 2022 Conference |
||
| May 16, 2022 |
NOTICE OF APPEARANCE (POST RJI) Notice of Appearance of Solmaz O. Mahalli |
||
| April 04, 2022 |
ORDER - PRELIMINARY CONFERENCE ADR forms still haven't been completed |
||
| March 16, 2022 | STIPULATION - CONFIDENTIALITY | ||
| March 16, 2022 |
PRELIMINARY CONFERENCE ORDER (PROPOSED) [Proposed] Amended Preliminary Conference Order |
||
| March 10, 2022 |
STIPULATION - OTHER - ( REQUEST TO SO ORDER ) STIPULATION AND ORDER FOR THE PRODUCTION AND EXCHANGE OF CONFIDENTIAL INFORMATION |
||
| March 03, 2022 |
LETTER / CORRESPONDENCE TO JUDGE LETTER DATED MARCH 3, 2022 TO JUDGE LINDA S\. JAMIESON REQUESTING THAT THE AMENDED PRELIMINARY CONFER LETTER DATED MARCH 3, 2022 TO JUDGE LINDA S\. JAMIESON REQUESTING THAT THE AMENDED PRELIMINARY CONFER ... show more
|
||
| March 03, 2022 | NOTICE OF BANKRUPTCY (PRE RJI) | ||
| January 19, 2022 |
ADJOURNMENT OF CONFERENCE -REQUEST LETTER TO JUDGE LINDA S\. JAMIESON DATED JANUARY 19, 2022 RE: REQUEST TO ADJOURN STATUS CONFERENCE
|
||
| December 30, 2021 |
EXHIBIT(S) - 2 (Motion #4) Exhibit 2 Plaintiffs affidavit of service |
||
| December 30, 2021 |
AFFIDAVIT OR AFFIRMATION IN SUPPORT OF CROSS-MOTION (Motion #4) Affirmation of Vincent J. Syracuse in Support of Cross-Motion |
||
| December 30, 2021 |
EXHIBIT(S) - 1 (Motion #4) Exhibit 1 Summons with Notice |
||
| December 30, 2021 |
EXHIBIT(S) - 3 (Motion #4) Exhibit 3 Plaintiffs affidavit of additional mailing |
||
| December 30, 2021 |
EXHIBIT(S) - 4 (Motion #4) Exhibit 4 Plaintiffs Verified Complaint |
||
| December 30, 2021 |
EXHIBIT(S) - 5 (Motion #4) Exhibit 5 Coopers bankruptcy letter to the court |
||
| December 30, 2021 |
EXHIBIT(S) - 3 (Motion #4) Exhibit 3 - Letter Withdrawing Agreement |
||
| December 30, 2021 |
AFFIDAVIT OR AFFIRMATION IN SUPPORT (Motion #4) Affidavit of Steven Wolin in Support of Cross-Motion |
||
| December 30, 2021 |
EXHIBIT(S) - 7 (Motion #4) Exhibit 7 Bankruptcy Court Order |
||
| December 30, 2021 |
EXHIBIT(S) - 1 (Motion #4) Exhibit 1 Cooper paystub redacted |
||
| December 30, 2021 |
EXHIBIT(S) - 8 (Motion #4) Exhibit 8 Cooper Mailing Envelope |
||
| December 30, 2021 |
EXHIBIT(S) - 6 (Motion #4) Exhibit 6 Plaintiffs Amended Verified Complaint (with exhibits 1-9) |
||
| December 30, 2021 |
EXHIBIT(S) - 2 (Motion #4) Exhibit 2 Proposed Agreement |
||
| December 30, 2021 |
NOTICE OF CROSS-MOTION (Motion #4) Notice of Cross-Motion |
||
| December 30, 2021 |
MEMORANDUM IN OPPOSITION TO MOTION AND IN SUPPORT OF CROSS-MOTION (Motion #4) Memorandum of Law in Opposition to Defendant Samuel F. Cooper's Motion to Dismiss and in Support of Memorandum of Law in Opposition to Defendant Samuel F. Cooper's Motion to Dismiss and in Support of ... show more |
||
| December 20, 2021 |
MEMORANDUM OF LAW IN REPLY (Motion #2) Defendants JTMM and Plut's Reply in Further Support of Their Motion to Dismiss |
||
| December 10, 2021 | NOTICE OF REJECTION | ||
| December 09, 2021 |
EXHIBIT(S) - 1 (Motion #2) AFFIRMATION OF VINCENT J. SYRACUSE EX. 1 |
||
| December 09, 2021 |
EXHIBIT(S) - 2 (Motion #2) AFFIRMATION OF VINCENT J. SYRACUSE EX. 2 |
||
| December 09, 2021 |
MEMORANDUM OF LAW IN OPPOSITION (Motion #2) PLAINTIFF'S MEMORANDUM OF LAW IN OPPOSITION TO THE PLUT/JTMM DEFENDANTS' MOTION TO DISMISS |
||
| December 09, 2021 |
AFFIDAVIT OR AFFIRMATION IN OPPOSITION TO MOTION (Motion #2) AFFIRMATION OF VINCENT J. SYRACUSE |
||
| December 09, 2021 | NOTICE OF MOTION (Motion #3) | ||
| December 09, 2021 |
EXHIBIT(S) - 3 (Motion #2) AFFIRMATION OF VINCENT J. SYRACUSE EX. 3 |
||
| November 17, 2021 | ORDER - PRELIMINARY CONFERENCE | ||
| November 09, 2021 |
EXHIBIT(S) - B (Motion #2) Master service agreement |
||
| November 09, 2021 | MEMORANDUM OF LAW IN SUPPORT | ||
| November 09, 2021 |
NOTICE OF MOTION (Motion #2) *Corrected* Notice of Motion to Dismiss |
||
| November 09, 2021 |
EXHIBIT(S) - A (Motion #2) Consulting agreement |
||
| November 09, 2021 | AFFIDAVIT OR AFFIRMATION IN SUPPORT OF MOTION | ||
| November 09, 2021 |
EXHIBIT(S) - C (Motion #2) Memo dated August 9, 2021 |
||
| November 09, 2021 |
EXHIBIT(S) - D (Motion #2) JTMM's bank statement dated May 31, 2020 |
||
| November 05, 2021 |
LETTER / CORRESPONDENCE TO JUDGE Letter to Judge Jamieson re: Joint Briefing Schedule |
||
| October 06, 2021 |
REPLY TO COUNTERCLAIM(S) VERIFIED REPLY TO COUNTERCLAIMS |
||
| October 05, 2021 |
LETTER / CORRESPONDENCE TO JUDGE LETTER DATED OCTOBER 5, 2021 TO JUDGE LINDA A\. JAMIESON RE: AN UPDATE TO THE COURT REGARDING THE BAN
|
||
| September 20, 2021 | NOTICE OF APPEARANCE (POST RJI) | ||
| September 16, 2021 |
ANSWER WITH COUNTER-CLAIM(S) Defendant JTMM Enterprises Inc.'s Verified Answer, Affirmative Defenses and Counterclaims |
||
| September 16, 2021 |
LETTER / CORRESPONDENCE TO JUDGE Pre-Motion Conference Request |
||
| August 27, 2021 |
EXHIBIT(S) - 2 VERIFIED COMPLAINT EX .2 |
||
| August 27, 2021 |
EXHIBIT(S) - 1 VERIFIED COMPLAINT EX .1 |
||
| August 27, 2021 |
EXHIBIT(S) - 8 VERIFIED COMPLAINT EX .8 |
||
| August 27, 2021 |
EXHIBIT(S) - 7 VERIFIED COMPLAINT EX .7 |
||
| August 27, 2021 |
EXHIBIT(S) - 3 VERIFIED COMPLAINT EX .3 |
||
| August 27, 2021 |
EXHIBIT(S) - 5 VERIFIED COMPLAINT EX .5 |
||
| August 27, 2021 |
EXHIBIT(S) - 9 VERIFIED COMPLAINT EX .9 |
||
| August 27, 2021 |
COMPLAINT (AMENDED) VERIFIED AMENDED COMPLAINT |
||
| August 27, 2021 |
EXHIBIT(S) - 4 VERIFIED COMPLAINT EX .4 |
||
| August 27, 2021 |
EXHIBIT(S) - 6 VERIFIED COMPLAINT EX .6 |
||
| August 11, 2021 | STIPULATION - TIME TO ANSWER | ||
| August 11, 2021 | DECISION + ORDER ON MOTION | ||
| August 09, 2021 |
NOTICE OF APPEARANCE (POST RJI) NOTICE OF APPEARANCE OF MARYANN C. STALLONE ON BEHALF OF THE RELIABLE AUTOMATIC SPRINKLER CO. INC. |
||
| August 09, 2021 |
NOTICE OF APPEARANCE (POST RJI) NOTICE OF APPEARANCE OF ROSA GUERRERO ON BEHALF OF THE RELIABLE AUTOMATIC SPRINKLER CO. INC. |
||
| August 09, 2021 |
LETTER / CORRESPONDENCE TO JUDGE LETTER DATED AUGUST 9, 2021 TO JUDGE LINDA A. JAMIESON RE: AN UPDATE TO THE COURT REGARDING THE BAN LETTER DATED AUGUST 9, 2021 TO JUDGE LINDA A. JAMIESON RE: AN UPDATE TO THE COURT REGARDING THE BAN ... show more
|
||
| August 02, 2021 |
PRELIMINARY CONFERENCE ORDER (PROPOSED) [PROPOSED] PRELIMINARY CONFRENCE ORDER |
||
| July 27, 2021 |
LETTER / CORRESPONDENCE TO JUDGE Re: Bankruptcy |
||
| July 21, 2021 |
STIPULATION - TIME TO ANSWER Stipulation Extending Time to Answer and/or Move to August 19, 2021 |
||
| July 06, 2021 | AFFIRMATION/AFFIDAVIT OF SERVICE | ||
| July 01, 2021 | NOTICE OF APPEARANCE (POST RJI) | ||
| June 30, 2021 | ORDER ( PROPOSED ) | ||
| June 30, 2021 |
AFFIDAVIT OR AFFIRMATION IN SUPPORT OF MOTION (Motion #1) Affirmation of Kevin J. O'Connor in Support of Motion for Admission Pro Hac Vice of Devin B. Phillip Affirmation of Kevin J. O'Connor in Support of Motion for Admission Pro Hac Vice of Devin B. Phillip ... show more |
||
| June 30, 2021 |
NOTICE OF APPEARANCE (POST RJI) Notice of Appearance and Demand for Complaint |
||
| June 30, 2021 |
NOTICE OF MOTION (Motion #1) Notice of Motion to Admit Devin B. Phillips Pro Hac Vice |
||
| June 30, 2021 |
AFFIDAVIT OR AFFIRMATION IN SUPPORT (Motion #1) Affidavit of Devin B. Phillips in Support of Motion for Admission Pro Hac Vice |
||
| June 28, 2021 |
COMPLAINT Verified Complaint |
||
| June 17, 2021 | LETTER/CORRESPONDENCE FROM COURT | ||
| June 17, 2021 |
RJI -RE: REQUEST FOR PRELIMINARY CONFERENCE REQUEST FOR JUDICIAL INTERVENTION, ASSIGNMENT TO COMMERCIAL DIVISON |
||
| June 17, 2021 |
PRELIMINARY CONFERENCE ORDER (PROPOSED) Please be sure to complete the 3 mandatory ADR forms attached at the end of this PC order prior to y Please be sure to complete the 3 mandatory ADR forms attached at the end of this PC order prior to y ... show more |
||
| June 17, 2021 | ADDENDUM - COMMERCIAL DIVISION (840C) | ||
| June 02, 2021 | AFFIRMATION/AFFIDAVIT OF SERVICE | ||
| May 25, 2021 |
AFFIRMATION/AFFIDAVIT OF SERVICE AFFIDAVIT OF SERVICE OF SUMMONS WITH NOTICE AND NOTICE OF ELECTRONIC FILING UPON JOHN PLUT |
||
| May 25, 2021 |
AFFIRMATION/AFFIDAVIT OF SERVICE AFFIDAVIT OF NAIL AND MAIL OF SUMMONS WITH NOTICE OF SAMUEL F. COOPER |
||
| May 25, 2021 |
AFFIRMATION/AFFIDAVIT OF SERVICE AFFIDAVIT OF ATTEMPTED SERVICE OF SUMMONS WITH NOTICE UPON JTMM ENTERPRISES, INC. |
||
| May 25, 2021 |
AFFIRMATION/AFFIDAVIT OF SERVICE AFFIDAVIT OF SERVICE OF SUMMONS WITH NOTICE AND NOTICE OF ELECTRONIC FILING UPON JTMM ENTERPRISES, I AFFIDAVIT OF SERVICE OF SUMMONS WITH NOTICE AND NOTICE OF ELECTRONIC FILING UPON JTMM ENTERPRISES, I ... show more |
||
| March 24, 2021 | SUMMONS WITH NOTICE |
