Case 2:13-cv-06218-SM-DEK Document 1 Filed 05/21/13 Page 1 of 106
.,

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF MISSISSIPPI
SOUTHERN DIVISION

SOUTMfRN DISTRICT OF MISSISSIPPI
FII ED
MAY 212013

LAKSHMANAN PONNAYAN ACHARI, KODAKERIL BABY BIJI, XAVIER DISOLIYAN, RAJANKUNJU GEEVARGHESE, JOMON GEORGE, SHAIJU VADAKKAL GEORGE, MOULESWARARAO GUNTAMUKKALA, JOY JACOB, BIJU JOHN, SHIBU JOSEPH, SUNILKUMAR MAROTTIKKAL KUTTAN, PARSHOTTAM RAMCHANDRA MANGANI, PRAKASH MOSES KANAGIAH MANONMONI, ADHARSAN MANUEL, JACOB MAZHUKKATTU MATHEW, JOHNY MATHEW, NANDHAKUMAR NAGARAJ, SHAJI VELUTHALAKUZHlYIL NANOO, MANGALAN CHANDRASEKHARAN PILLAI, RADHAKRISHNA PILLAI SIVARAMA PILLAI, ABY MOLATHU POULOSE, JUSTIN POULOSE, APPUNNI ARUL PRAKASH, SREENIVASARAO RAPARTHY, MOOKAPARAMBIL ITTY RAVEENDRANATHAN, BALWINDER SINGH, RANJIT SINGH, SHANMUGAM SUBRAMANIAN, NINAN JOHN THARAKAN, GEORGE PULIKKEPARAMBIL VARGHESE, BENNY KATTUKARIYIL VARKEY, SHAHl VIJAYAN, and JOHN YOHANNAN,

J T N08l1N CLERK

BY

oepUTY

Civ. No.1: l3.c,,~~d.. LC, - UIY'IC

Plaintiffs,

v.

SIGNAL INTERNATIONAL, LLC, SIGNAL INTERNATIONAL, INC., MALVERN C. BURNETT, LAW OFFICES OF MALVERN C. BURNETT, A.P.C., GULF COAST IMMIGRAnON LAW CENTER, LLC, MICHAEL POL, GLOBAL RESOURCES, INC., SACHIN DEWAN, and DEWAN CONSULTANTS PVT. LTD. (alk/a MEDTECH CONSULTANTS),

Defendants.

COMPLAINT AND JURY DEMAND

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TABLE OF CONTENTS
Page
INTRODUCTION ........................................................................................................................... 1
Defendants' Conduct Violated Congress's Clear Prohibition Against Human Trafficking .....................................................................................................................7
JURISDICTION AND VENUE ...................................................................................................... 8
PARTIES .........................................................................................................................................9
SUBSTANTIVE ALLEGATIONS ............................................................................................... 14
In the Aftermath of Hurricane Katrina, Signal Contracts with Dewan, Burnett, and Pol to Bring Temporary Workers to the United States at No Cost to SignaJ... ............ 14
Defendants File Petitions for Temporary H-2B Visas, Not Green Cards ..........................16
Plaintiffs Incur Substantial Debt to Afford High "Recruitment Fees" ............................. .18
Plaintiffs Arrive in Signal's Pascagoula, Mississippi Man Camp and are Subjected to Degrading and Discriminatory Conditions ..............................................................20
Plaintiffs Experienced Other Discrimination by Signal and its Employees Due to their Race, Ethnicity, Religion, and Alienage..............................................................25
Signal and the Agents Continued to Mislead the Plaintiffs About the Terms of their Employment.........................................................................................................27
In an Attempt to Quell Rising Worker Dissatisfaction, Signal Sends Three Workers Back to India, One of Whom Attempts Suicide ............................................29
Signal, Assisted by Burnett and Dewan, Used Fraudulent and Coercive Tactics to Keep Plaintiffs in the Pascagoula Camp ......................................................................30
Malvern Burnett Purported to Act as Attorney to Plaintiffs, but In Reality Was Working Solely on BehalfofDefendants ................................................................... .31
Plaintiffs Each Relied on the Defendants' Representations ..............................................34
FIRST CLAIM FOR RELIEF .......................................................................................................92
THE TRAFFICKING VICTIMS PROTECTION REAUTHORIZATION ACT ("TVPRA") OF 2003 - Forced Labor (18 U.S.C. § 1589) and Trafficking with Respect to Peonage, Slavery, Involuntary Servitude, or Forced Labor (18 U.S.C. § 1590) .............................................................................................................92

-- - - - ----- - - - - - - -
Case 2:13-cv-06218-SM-DEK Document 1 Filed 05/21/13 Page 3 of 106 SECOND CLAIM FOR RELIEF ..................................................................................................95
VIOLATIONS OF THE CIVIL RIGHTS ACT OF 1866 - 42 U.S.C. § 1981 ..................95 THIRD CLAIM FOR RELIEF ......................................................................................................96
FRAUDULENT MISREPRESENTATION ......................................................................96 FOURTH CLAIM FOR RELIEF ..................................................................................................98
NEGLIGENT MISREPRESENTATION ..........................................................................98 FIFTH CLAIM FOR RELIEF ..................................................................................................... 100
BREACH OF CONTRACT................................................................................. _........... 100 PRAYER FOR RELIEF .............................................................................................................. 102 DEMAND FOR JURY TRIAL ................................................................................................... 102
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INTRODUCTION 1. This is a human trafficking case brought by foreign workers trafficked into the State of Mississippi. It is grounded in laws passed by the United States Congress to combat this very problem. Rather than hiring new workers from the Gulf Coast in the wake of a devastating hurricane, the Defendants instead turned the Plaintiffs into an exploitable source of cheap labor. The Defendants then worked together to defraud each of the Plaintiffs out of tens of thousands of dollars, falsely promised them assistance in applying for and obtaining permanent residence in the United States, trafficked them into the United States, forced them to live in squalid and unsanitary conditions that damaged Plaintiffs' health and psychological well-being, discriminated against them on the basis of their race, ethnicity, religion, and alienage, and threatened them with financial ruin and adverse immigration action if they balked. 2. Plaintiffs Lakshmanan Ponnayan Achari, Kodakeril Baby Biji, Xavier Disoliyan, Rajankunju Geevarghese, Jomon George, Shaiju Vadakkal George, Mouleswararao Guntamukkala, Joy Jacob, Biju John, Shibu Joseph, Sunilkumar Marottikkal Kuttan, Parshottam Ramchandra Mangani, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Jacob Mazhukkattu Mathew, Johny Mathew, Nandhakumar Nagaraj, Shaji Veluthalakuzhiyil Nanoo, Mangalan Chandrasekharan Pillai, Radhakrishna Pillai Sivarama Pillai, Aby Molathu Poulose, Justin Poulose, Appunni Arul Prakash, Sreenivasarao Raparthy, Mookaparambil !tty Raveendranathan, Balwinder Singh, Ranjit Singh, Shanmugam Subramanian, Ninan John Tharakan, George Pulikkeparambil Varghese, Benny Kattukariyil Varkey, Shahi Vijayan, and John Yohannan, each a former employee at Signal International, LLC and Signal International, Inc.'s (collectively "Signal") Pascagoula, Mississippi facility, bring this action to recover for the unlawful and fraudulent behavior by Defendant Signal and Signal's agents Malvern C. Burnett, the Law Offices of Malvern C. Burnett, Gulf Coast Immigration Law Center, LLC, Sachin
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Dewan, Dewan Consultants Pvt. Ltd., Michael Pol, and Global Resources Inc. (referred to hereafter as the "Agents").
3. Signal is a Gulf Coast-based marine and fabrication company. In the aftermath of Hurricane Katrina, Signal set out to recruit several hundred foreign workers to work as temporary welders and pipefitters in Signal's Pascagoula, Mississippi facility. Signal also recruited workers to work at a Signal facility in Orange, Texas.
4. To assist in that process, Signal retained Michael Pol and his company Global Resources, Inc. ("Global"), a labor recruitment firm with operations in Mississippi; Malvern C. Burnett, an attorney based in Mississippi and Louisiana; and Sachin Dewan, a labor recruiter in India, to recruit workers on Signal's behalf. Signal also executed a power of attorney authorizing Dewan's company, Dewan Consultants Pvt. Ltd., to recruit for Signal abroad.
5. The cornerstone of the Defendants' scheme was the tantalizing prospect that Signal would be able to hire a skilled workforce at effectively no cost by forcing the Plaintiffs and their coworkers to foot the bill for their own recruitment, immigration processing, and travel. Indeed, an April 18, 2006 "Skilled Worker Recruitment Agreement" between Signal and Global that set this scheme in motion expressly stated that the workers would be delivered at no cost to Signal and that all other charges, expenses and fees would be paid by the workers themselves or by Global, who in tum would be reimbursed through deductions from the Plaintiffs' wages. In short, Defendants paid nothing; the future employees paid everything.
6. Begirming in mid-2006, Signal, both via its own employees and via its external Agents, traveled to India in order to recruit workers, including each of the Plaintiffs. In printed advertisements and in-person meetings in India, Defendants promised Plaintiffs that in exchange for "recruitment fees" payable to the Agents ranging anywhere from the equivalent of $1 0,000 to
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$25,000, Defendants would provide Plaintiffs with jobs at Signal and assist them in applying for and receiving green cards.
7. Defendants told Plaintiffs that because the permanent residency process could take up to two years to complete and Signal's need for workers was immediate, Defendants would first assist Plaintiffs in obtaining temporary work visas, known as H-2B visas, while simultaneously applying for green cards.
8. Lured by the promise of, in the words of one of the Defendants' advertisements, the opportunity for "permanent lifetime settlement in the U.S.A. for self and family," Plaintiffs took on immense burdens to gather enormous fees, often by selling family assets and incurring significant debt at usurious rates. Plaintiffs did this because they believed they would recoup the expense with the high wages they were promised at Signal, and through the long-term employment opportunities that would be available to them and their families as permanent residents of the United States.
9. In actuality, the Defendants' promises regarding green cards for Plaintiffs were illusory. Defendants had not taken, and had no intention at that time of taking, any steps to assist the Plaintiffs in applying for or receiving green cards. To the contrary, Signal (with the knowledge and assistance of the Agents) represented to the United States government that it would employ the workers only temporarily, and that the workers would be returned to India "within the...year." At no point did Signal or any of the Agents take any steps to assist and Plaintiff in applying for or receiving a green card.
10. Plaintiffs, of course, were never told of Signal's representations to the United States government. The Plaintiffs were unaware that Defendants' promises of employment and permanent residency were false and relied on these false promises to their detriment.
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11. Put simply, Plaintiffs had been deceived into taking on life-altering debt for something that was never going to happen.
12. Upon arrival at Signal's facilities in Mississippi, Plaintiffs' plight only worsened. Signal utilized psychological abuse, coercion, and fraud to leave Plaintiffs afraid and unable to leave Signal's facilities and employ. Plaintiffs were required to live in camps on Signal's Pascagoula premises, enduring barbaric and prison-like conditions. Plaintiffs were among several hundred men crammed into trailer-like bunkhouses that were far too small for the number of men housed therein, and otherwise unfit for human habitation. Privacy was non-existent. Toilet and bathing facilities were insufficient. Food was often rotten. Private "security guards" patrolled the grounds like prison guards, prevented the Plaintiffs from leaving, and subjected the Plaintiffs to random searches of their persons and belongings.
13. Signal sought to deflect as much of the housing costs as possible onto the Plaintiffs. For the "privilege" ofliving in prison-like squalor, Signal deducted $35 per day from Plaintiffs' paychecks, seven days a week, which constituted over 34% of the workers' pre-tax earnings. When workers requested permission to live off-site, they were told by Signal that they could do so, but that Signal would continue to collect the $35 per day. This compulsory deduction essentially prohibited Plaintiffs from living in more humane conditions, lest their work become even less remunerative, and consequently their "recruiting fee" debt become even more crushing.
14. Non-Indian workers were not subjected to such squalid living conditions, degrading treatment, or extortionate room and board policies.
IS. Plaintiffs were also made to work in unsafe working conditions that non-Indian workers were not subjected to, and were forced to endure regular anti-Indian invective from
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Signal personnel, along with threats to deport them if they did not do Signal's every bidding. Indeed, Signal housed Plaintiffs in the so-called "man camps" so that they would not mix with the Pascagoula community. The Signal executive supervising the Pascagoula man camp referred to the facility-privately and in professional correspondence to other Signal employees-as "the Reservation," a term adopted from Signal's "shipyard folks." Another Signal employee was more direct, promising Signal management on April 5, 2007 that if he were placed in charge of the man camp, he would not give in to the "misguided notion that some of these Indians can be
reasoned with" but would instead "most defiantly [sic1go on a 'rat hunt.",
16. Signal even forced men of Sikh heritage to shave their beards upon arriving in the camp. Wearing of a beard is an extremely important religious tradition to Sikh men, and Signal's coercion left the men, including Plaintiff Ranjit Singh, reduced to tears.
17. Conditions were so poor at Signal's Pascagoula facility that, after just a couple months, workers (including Plaintiffs) began to consider ways to convince Signal to improve conditions. In retaliation for the workers' attempts to improve their lot, Signal terminated the employment of three of the most outspoken workers, forcibly removed them from the camp and told them they would be immediately returned them to India. One of those expelled men, so distraught over the thought of returning to India with the crushing debt of the "recruitment fees," attempted suicide in front of one of the Plaintiffs.
18. Signal used this horrifying incident to its advantage. In a meeting with the workers (including the Plaintiffs) days after the attempted suicide, Signal told Plaintiffs that if any of the Signal workers filed a lawsuit against Signal, Signal would send all of the workers back to India. The Plaintiffs understood this to mean that they must remain quiescent and work, lest Signal retaliate and ruin them financially.
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19. Signal employed other methods of forcing the Plaintiffs to endure the abusive

conditions. In keeping with its focus on deflecting labor costs, upon Plaintiffs' arrival, Signal required workers to set up "direct deposit" bank accounts with a local bank, to which Signal also

had access. These accounts gave Signal control over the worker's ability to leave the facility

because Signal could threaten to cut off the workers' access to the accounts at any point. Indeed,

this is exactly what happened-in April, 2007, after certain workers fled the Pascagoula camp,

those workers were denied access to their accounts, at the behest of Signal. This had the

intended effect of intimidating and coercing the remaining workers, including Plaintiffs, into

compliance. 20. Deeply indebted, fearful, isolated, disoriented, and unfamiliar with their rights

under United States law, Plaintiffs felt compelled to continue working for Signal, on Signal's

onerous terms and in abusive conditions.

21. In line with Signal's original intention as expressed to the United States

government-but not to the Plaintiffs-to employ the workers temporarily, Plaintiffs were all

terminated within a year and a half of arriving in Pascagoula, or left to escape the horrid

conditions. 22.

At no point did Signal or the Agents ever apply for, or assist Plaintiffs in applying

for, permanent residency. Moreover, consistent with its never-failing effort to improve its

bottom line by transferring as many costs associated with their employment as possible back

onto Plaintiffs, Signal never refunded the tens of thousands of dollars in "recruitment fees"

Plaintiffs had paid in exchange for less than one year of low-paid work. None of the Plaintiffs

earned enough money at Signal to make the exorbitant and debt-inducing "recruitment fees"

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even remotely worthwhile. Moreover, Signal never compensated Plaintiffs in any way for the

physical, emotional, and psychological degradations inflicted upon them at the Pascagoula camp.

23. In short, and as will be alleged more fully below, Defendants' promises of

employment-based green cards were fictional:

•

Defendants never filed or otherwise supported green card applications for

Plaintiffs, or took any other steps toward assisting Plaintiffs with securing

green cards;

•

Defendants told United States Department of Homeland Security under

penalty of perjury that Signal's need for workers was temporary;

•

Signal has stated in court filings that it never intended to provide the

workers with green cards, but rather with temporary H-2B visas;

•

Defendants segregated and confined Plaintiffs and other Indian workers to

the man camp because Defendants did not want Indian workers mixing

with other members of the Pascagoula community; and

•

Internal correspondence among Signal management in May 2006 shows

that "[a)ll [Signal is) doing now is bringing the workers in under the H2B

program."

Defendants' Conduct Violated Congress's Clear Prohibition Against Human Trafficking 24. In 2000, Congress enacted the Victims of Trafficking and Violence Protection Act

("TVPA") to provide enhanced legal protections for victims of human trafficking and to

supplement existing forms of relief. Congress specifically included protections for persons

forced to work out of fear of serious harm, physical restraint, abuse of the legal process, or

threats of the same.

25. According to House Report I 06-939, the new statute was "intended to address the

increasingly subtle methods of traffickers who place their victims in modem-day slavery, such as

where traffickers threaten harm to third persons, restrain their victims without physical violence

or injury, or threaten dire consequences by means other than overt violence." In particular,

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Congress clarified that the statute covered "a broad array of harms, including both physical and nonphysical," and could apply where the perpetrator "intentionally caus[ed] the victim to believe that her family [would] face harms such as banishment, starvation, or bankruptcy in their home country."
26. In 2003, Congress amended the statute to permit individual victims of trafficking to bring civil claims against their traffickers. Plaintiffs do so here. Plaintiffs also bring claims for violations of the Civil Rights Act of 1866, fraudulent misrepresentation, negligent misrepresentation, and breach of contract.
JURISDICTION AND VENUE 27. This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C. § 1331 (federal question jurisdiction), 18 U.S.C. § 1595(a) (civil trafficking), 28 U.S.c. § 1343 (civil rights), and 28 U.S.C. § 1367 (pendent state law claims). 28. This Court has personal jurisdiction over Signal pursuant to Fed. R. Civ. P. 4(k) and Miss. Code § 13-3-57 as Signal maintains a continuing business presence in the state, including but not limited to two shipyards in Pascagoula, Mississippi, where the workers worked and most of the wrongful conduct alleged herein occurred. This Court also has personal jurisdiction under Fed. R. Civ. P. 4(k) and Miss. Code § 13-3-57 over Pol, a resident of Mississippi; Global Resources, Inc., which is incorporated under the laws of Mississippi; Burnett, who is registered to vote and practices law in Mississippi; and the Law Offices of Malvern C. Burnett and Gulf Coast Immigration Law Center, LLC, which have offices in Ocean Springs, Mississippi and where much of the legal work alleged herein was performed. This Court has personal jurisdiction over Dewan and Dewan Consultants, Ltd. under Fed. R. Civ. P. 4(k) and Miss. Code § 13-3-57. Dewan Consultants Ltd. contracted with Pol and Burnett and served as Signal's agent to recruit workers and deliver them for employment in Mississippi.
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Dewan, both individually and on behalf of Dewan Consultants Ltd., traveled to Pascagoula,

Mississippi, in connection with the events described herein. 29. Venue is proper in this district under 28 U.S.c. § 1391 in that much of

Defendants' trafficking activity, civil rights violations, fraud, misrepresentations, and breach of

contract occurred within this judicial district.

PARTIES Plaintiffs 30. All Plaintiffs are Indian nationals, of Indian race and ethnicity, and former H-2B

guest workers who were recruited from India by Defendants in or about 2006 and worked at

Signal's Pascagoula, Mississippi facility after arriving in the United States. Plaintiffs each paid

the Agents the equivalent of between $10,000 and $25,000 in "recruitment fees" based on the

false promise that they would assist them in applying for and receiving green cards. Plaintiffs

were each subjected to discriminatory, dangerous, and abusive treatment upon their arrival at

Signal. 31.

Plaintiff Lakshmanan Ponnayan Achari was recruited beginning in or about April

of2006 and arrived in the United States on or about December 5, 2006.

32. Plaintiff Kodakeril Baby Biji was recruited beginning in or about July of 2006

and arrived in the United States on or about December 5, 2006. 33. Plaintiff Xavier Disoliyan was recruited beginning in or about June and July of

2006 and arrived in the United States on or about November 20, 2006.

34. Plaintiff Rajankunju Geevarghese was recruited beginning in or about April of

2006 and arrived in the United States on or about November 28,2006.

35. Plaintiff lomon George was recruited beginning in or about April or May of 2006

and arrived in the United States on or about Nov. 28, 2006. 9

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36. Plaintiff Shaiju Vadakkal George was recruited beginning in or about April and May of2006 and arrived in the United States on or about November 28,2006.
37. Plaintiff Mouleswararao Guntamukkala was recruited beginning on or about May 23,2006 and arrived in the United States on or about January 24, 2007.
38. Plaintiff Joy Jacob was recruited beginning in or about 2006 and arrived in the United States in or about 2006.
39. Plaintiff Biju John was recruited beginning in or about April or May of2006 and arrived in the United States on or about November 20, 2006.
40. Plaintiff Shibu Joseph was recruited beginning in or about April or May of 2006 and arrived in the United States on or about November 28, 2006.
41. Plaintiff Sunilkumar Marottikkal Kuttan was recruited in beginning in or about Mayor June of 2006 and arrived in the United States on or about December 7, 2006.
42. Plaintiff Parshottam Ramchandra Mangani was recruited beginning in or about April-July of 2006 and arrived in the United States on or about November 6, 2006.
43. Prakash Moses Kanagiah Manonmoni was recruited beginning in or about July of 2006 and arrived in the United States on or about November 28, 2006.
44. Prakash Adharsan Manuel was recruited beginning in or about June of 2006 and arrived in the United States on or about November 16,2006.
45. Plaintiff Jacob Mazhukkattu Mathew was recruited beginning in or about June or July 0[2006 and arrived in the United States on or about December 7, 2006.
46. Plaintiff Johny Mathew was recruited beginning in or about March of 2006 and arrived in the United States on or about November 29, 2006.
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47. Plaintiff Nandhakumar Nagaraj was recruited beginning in or about Mayor June of 2006 and arrived in the United States on or about November 26, 2006.
48. PlaintiffShaji Veluthalakuzhiyil Nanoo was recruited beginning in or about April or May of 2006 and arrived in the United States on or about November 28, 2006.
49. Plaintiff Mangalan Chandrasekharan Pillai was recruited beginning in or about June 2006 and arrived in tbe United States on or about November 20,2006.
50. Plaintiff Radhakrishna Pillai Sivarama Pillai W(lS recruited beginning in or about. May of2006 and arrived in the United States on or about November 19,2006,
51. Plaintiff Aby Molathu Poulose was recruited beginning in or about March or April of 2006 and arrived in the United States on or about November 18, 2006.
52, Plaintiff Justin Poulose was recruited beginning in or about the summer of 2006 and arrived in the United States on or about November 20, 2006.
53. Plaintiff Appunni Arul Prakash was recruited beginning in or about April or May of2006 and arrived in the United States on or about November 27, 2006.
54. Plaintiff Sreenivasarao Raparthy was recruited beginning on or about June 26, 2006 and arrived in the United States on or about November 29,2006.
55. Plaintiff Mookaparambil Ilty Raveendranathan was recruited beginning in or about late 2005 and arrived in the United States on or about December I, 2006,
56. Plaintiff Balwinder Singh was recruited beginning in or about 2006 and arrived in the United States in or about 2006.
57. Plaintiff Ranjit Singh was recruited beginning in or about Mayor June 2006 and arrived in the United States on or about October 30, 2006.
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58. Plaintiff Shanmugam Subramanian was recruited beginning in or about April of 2006 and arrived in the United States on or about November 28, 2006.
59. PlaintiffNinan John Tharakan was recruited beginning in or about May of 2006 and arrived in the United States on or about November 26, 2006.
60. Plaintiff George Pulikkeparambil Varghese was recruited beginning in or about August 2006 and arrived in the United States on or about January 24, 2007.
61. Plaintiff Benny Kattukariyil Varkey was recruited beginning in or about February or March of2006 and arrived in the United States on or about November 28, 2006.
62. Plaintiff Shahi Vijayan was recruited beginning in or about March or April of 2006 and arrived in the United States on or about November 20, 2006.
63. Plaintiff John Yohannan was recruited beginning in or about May of 2006 and arrived in the United States in or about November of 2006.
Defendants 64. Defendants Signal International, LLC and Signal International, Inc. are corporations organized under the laws of Delaware, with facilities in the Gulf Coast region, including Pascagoula, Mississippi. At all relevant times, Signal International, LLC acted as an agent and/or alter ego of Signal International, Inc., and took all conduct discussed herein with the knowledge and consent of Signal International Inc. Signal International, LLC and Signal International, Inc. will be referred to collectively below as "Signal" unless a distinction is drawn between them. Signal provides marine and fabrication services, including offshore drilling rig overhaul, repair, upgrade and conversion. 65. Defendant Global Resources, Inc. ("Global") is a corporation organized under the laws of Mississippi that recruits workers from India for employment in the United States.
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66. Defendant Michael Pol ("Pol") was, at all relevant times, the President of Global

Resources, Inc., and resides in Mississippi. On information and belief, Pol was, at all relevant

times, the sole corporate officer of Global. Pol and Global Resources, Inc. are alter egos. Global

and Pol will be referred to collectively below as "Pol," unless a distinction is drawn between

them. 67.

Defendant Dewan Consultants Pvt. Ltd. (alkla Medtech Consultants) ("Dewan

Consultants") is a private limited liability company organized under the laws of India. Dewan

Consultants has substantial business contacts with Pascagoula, Mississippi. In 2004, Dewan

Consultants contracted with Global and Burnett - through the Gulf Coast Immigration Law

Center, LLC - to identify and recruit Indian workers for employment in the United States on

permanent residency visas.

68. Defendant Sachin Dewan ("Dewan") is the Director of Dewan Consultants.

Dewan resides in India and has, since at least 2005, had substantial business contacts with

Pascagoula, Mississippi, including travel to Pascagoula on behalf of Signal and Dewan

Consultants. Dewan and Dewan Consultants will be referred to collectively below as "Dewan,"

unless a distinction is drawn between them.

69. Defendant Malvern C. Burnett ("Burnett") is an attorney who is registered to vote

in Mississippi and maintains offices in Ocean Springs, Mississippi. Burnett used his Ocean

Springs office to perform much ofthe legal work necessary to bring Plaintiffs and other Indian

workers to the United States on H-2B Visas.

70. Defendant Law Offices of Malvern C. Burnett, A.P.C. ("Burnett Law Offices") is

a professional law corporation organized under the laws of Louisiana that maintains offices in

Ocean Springs, Mississippi.

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71. Defendant Gulf Coast Immigration Law Center, LLC ("Gulf Coast Immigration") is a limited liability corporation organized under the laws of Louisiana that maintains offices Mississippi. Burnett is the registered agent of Gulf Coast Immigration. On information and belief, Burnett is the sole member andlor corporate officer of Gulf Coast Immigration. Burnett, the Burnett Law Offices and Gulf Coast Immigration operated as a joint venture andlor alter egos, and will be referred to collectively below as "Burnett," unless a distinction is drawn between them.
72. At all relevant times, the Agents acted as the agents andlor representatives of Signal, and were acting within the course and scope of their agency, with the full knowledge, consent, permission, authorization and ratification, either express or implied, of Signal in performing the acts alleged in this complaint.
73. At all relevant times, the Agents were involved in a venture with each other to recruit the Indian workers, including the Plaintiffs, and bring them to the United States to work at Signal, as memorialized by various oral and written communications and agreements, and were acting within the course and scope of that venture and those agreements, with the full knowledge, consent, permission, authorization and ratification, either express or implied, of each of the other Agents in performing the acts alleged in this complaint.
SUBSTANTIVE ALLEGATIONS In the Aftermath ofHurricane Katrina, Signal Contracts with Dewan, Burnett, and Pol to
Bring Temporary Workers to the United States at No Cost to Signal 74. The devastation caused by Hurricane Katrina presented both an opportunity and a challenge for Signal. The rebuilding effort offered significant potential for new work fixing damaged oil rigs, ships, and other marine platforms. At the same time, however, because the
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hurricane also destroyed or damaged thousands of homes along the Gulf Coast, including in Pascagoula, some of Signal's workforce had temporarily left the area.
75. In early 2006, Michael Pol approached Signal with a purported solution to its problem. At a meeting in January or February of 2006, Pol told Signal's Chief Financial Officer Chris Cunningham, Senior Vice President and General Manager Ronald Schnoor, and Vice President of Productions for Mississippi Operations Bill Bingle, that he could deliver first-class fitters and welders from India at no cost to Signal. Pol informed Signal that he would work with local immigration attorney Burnett and India-based recruiter Dewan to bring skilled welders from India. The workers themselves would pay for all costs and fees associated with the recruitment process, immigration processing, and travel to the United States, and Signal would not reimburse the workers for these fees. Signal would pay the workers between $14 and $18 per hour, depending upon skill level.
76. On April 18,2006, Signal executed a document entitled "Skilled Worker Recruitment Agreement" (the "Recruitment Agreement") with Pol's company, Global, authorizing Global to recruit foreign skilled workers for employment at Signal "under the 'H-2B' temporary program andlor the 'permanent residence' process." Pursuant to the Recruitment Agreement, Global would be responsible for all costs associated with recruitment, transportation, and entry of the foreign workers into the United States and would deliver the workers "at no cost to Signal" to the airport of Signal's choice. The cost incurred by Pol would be deducted directly from the foreign workers' wages and paid to Pol/Global.
77. On June 19,2006, Signal executed a power of attorney with Dewan's company, Dewan Consultants, appointing Dewan Consultants as Signal's "representative in India to facilitate the recruitment of skilled workers to the United States of America" for employment at
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Signal. The power of attorney authorized Dewan Consultants to advertise, conduct seminars and

trade tests, and sign any necessary legal documentation on Signal's behalf. 78. Also in mid-2006, Signal entered into an attorney-client relationship with Burnett

to advise Signal on immigration issues pertaining to Signal's need for workers. Signal and

Burnett later memorialized their engagement in a written retainer agreement. Pursuant to that

agreement, Signal would not be responsible for any of Burnett's legal fees. Rather, under the

terms ofthe agreement, Burnett took funds from the "recruitment fees" charged to the workers to

pay for the legal services he provided to Signal. Defendants File Petitions for Temporary H-2B Visas, Not Green Cards
79. Signal requested that the Agents secure foreign workers and transport them to the

United States as quickly as possible. Signal and the Agents decided that Signal would sponsor

workers on an H-2B visa, which could later be extended if Signal needed more foreign labor.

80. In 2006, Dewan and Burnett placed newspaper advertisements in at least six

Indian cities to recruit workers for Signal. Some of the advertisements offered welders and

fitters opportunities to go to the United States and obtain H-2B visas or green cards. Other

advertisements touted the opportunity for "permanent lifetime settlement in U.S.A. for self and

family." 81.

In the spring, surnmer, and fall of 2006, Dewan, Pol, and Burnett traveled

multiple times to India and the United Arab Emirates to conduct recruitment seminars with

interested potential workers. At these various seminars, the Agents promised recruits, including

Plaintiffs, that Signal would sponsor green card applications for them. In their seminar

presentations, the Agents promised that although all hopeful green card applicants would

automatically be emolled as H-2B candidates, this would not affect the employment based green

card process. 16

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82. Signal and its Agents told the Plaintiffs that Signal would sponsor them immediately for green cards in order to induce them to pay large fees to travel to the United States-which had the net effect of defraying nearly all the costs Signal would have had to expend to recruit workers legitimately-and to induce them to pay exorbitant "recruitment fees" far in excess of what would actually be required by the Defendants to obtain H-2B visas or even the promised green cards.
83. Unbeknownst to the Plaintiffs, however, Defendants did not take any steps to apply for permanent residence for the Plaintiffs. Defendants only helped Plaintiffs obtain temporary, H-2B visas. Indeed, Signal made clear in its application to the United States Department of Homeland Security that its need for workers was temporary and short-lived.
84. Written agreements between Plaintiffs and the Agents also explicitly promised assistance in applying for and securing green cards-assistance that Defendants took no steps toward providing. Dewan Consultants had the workers, including Plaintiffs, sign "memoranda of understanding," which, among other things, informed the workers that "Signal International, LLC has orally promised the Facilitator [Dewan Consultants] ... that ... [Signal] will be willing to file and process their employment base [sic.] Green Card." Dewan Consultants also issued form letters to the workers once they were selected to travel to Signal, informing the workers that Signal "shall proceed with your Green Card for United States of America."
85. Several Signal employees, including Signal Special Projects Manager John Sanders and Vice-President of Productions for Mississippi Operations William Bingle, traveled to India and attended these sessions. Sanders also oversaw the immigration interviews and served as contact between Signal and consular officials.
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86. To ensure that their deception remained hidden, Defendants instructed Plaintiffs not to tell United States Department of Homeland Security officials during their forthcoming H2B visa interviews that, in addition to applying for temporary worker status, Signal had promised them that it would sponsor them for green cards. As Pol explained to Sanders in an August 24,
2006 email: Mal[vern Burnett], Sachin [Dewan] or I[] needs to be with each and every candidate going into the consulates before their interview [because] [t]hey sometimes say the dumbest things and need to be coached on the proper way to interview. . .. [T]here are some things that should not be known to the consulate personnel, such as the fact that we are going to process them for a green card. If one of those guys says he is going to the U.S. for immigration and Signal is sponsoring him for permanent residence (green card) ... he is a goner.
Plaintiffs Incur Substantial Debt to Afford High "Recruitment Fees" 87. Lured by the Agents' promises of high-paying employment and permanent residency in the United States, Plaintiffs relinquished stable employment opportunities in India
and as guest workers in the Persian Gulf. 88. Apart from foregoing additional financial gains, Plaintiffs also sold personal and
familial assets and incurred substantial debt to afford the fees demanded by Defendants for their
recruitment and travel to the United States. 89. These fees, quoted in various amounts to Plaintiffs, ranged from the equivalent of
approximately $10,000 to $25,000. 90. The Agents knew that these fees would cause the workers, including Plaintiffs, to
incur substantial and potentially ruinous debt. 91. Each Plaintiff paid the amounts Defendants requested, as detailed in further
allegations below.
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92. Before receiving their visas, Plaintiffs were interviewed by officials at the U.S. consulate in India. Prior to these interviews, Dewan and other employees of Dewan Consultants met with Plaintiffs, took their passports, and, at the direction of Burnett, instructed them to tell consular officials that they only paid a total of approximately $670 in recruiting and immigration processing fees.
93. Dewan told Plaintiffs that if they told the truth about the significant fees they had paid, their visas would be cancelled and the Agents would keep the money they had already collected.
94. Even in the face of significant delays in processing immigration paperwork, which left the Plaintiffs jobless and uncertain of their future, Dewan, Pol, and Burnett refused to refund any fees for any reason. When certain Plaintiffs, including Shaiju Vadakkal George and Aby Molathu Poulose, expressed reluctance to continue with the immigration process or pay the next fee installment, Dewan, Pol, and Burnett threatened forfeiture of all money paid to that point. Defendants also loaded new, unexplained fees onto the workers, from minor fees (such as $45 "testing fees") to significant additional last-minute travel expenses.
95. In the hours before their flights to the United States departed, Plaintiffs were required to wait in line to proceed through Dewan Consultants' cramped offices to make a final installment payment in cash. Dewan then forced Plaintiffs to sign various documents - many written in English, which certain of the Plaintiffs could not read or understand - in a rushed fashion. Dewan even refused to tell Plaintiffs what it was they were signing. Only then did Dewan return Plaintiffs' passports to them.
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96. Thereafter, each Plaintiff boarded a flight to the United States, where they were

picked up from the airport by Signal personnel and taken to Signal's Pascagoula, Mississippi

facility.
Plaintiffs Arrive in Signal's Pascagoula, Mississippi Man Camp and are Subjected to Degrading and Discriminatory Conditions
97. Signal assigned each Plaintiff to work at its Pascagoula, Mississippi fabrication

facility. 98.

Signal required that each Plaintiff live in a man camp constructed in the fall of

2006 specifically to house Indian workers. Signal employees and management referred to the

Pascagoula man camp as "the Reservation." 99. Signal personnel discussed among themselves, including in written email

communication, that housing the workers in a secluded man camp on the outskirts of town was

preferable, as it would keep the Indians segregated from the rest of the Pascagoula, Mississippi

community. I00. The Pascagoula man camp was isolated, over-crowded, unsanitary, and not

suitable for human habitation. Workers were not permitted to photograph the man camp.

Overcrowded Bunkhouses 101. The camp bunkhouses themselves were not fit for long-term human habitation.

Signal crammed up to twenty-four men into each bunkhouse. The bunk beds were so tightly

packed that it was difficult for the Plaintiffs to move between them. The top bunks were so close

to the ceiling and the bottom bunks so close to the top bunks that Plaintiffs could barely sit up in

their beds.

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102. The bunkhouses had insufficient toilet and showering facilities. Lines for the bathroom were consistently very long. The showers themselves were dangerous. Electrical conduit joints near the showers were unglued, exposing workers to potential electrocution.
103. Privacy was impossible, and sleep was difficult, due to the noise from such close quarters, oppressive smells, and the comings and goings of workers who worked on different shifts. Some workers reported rats in their sleeping areas. Occasionally, rats ran across their bodies.
104. These conditions fell far short of basic requirements of habitability. For example, the federal government's Occupational Safety and Health Administration ("OSHA") guidelines state that bunkhouses of similar purpose should have a minimum of 50 square feet of floor space per habitant. Signal's bunkhouses offered less than 18 square feet of floor space per worker. Likewise, OSHA guidelines require bunk beds to be at least 48 inches apart from other beds. Signal's bunk beds were so tightly packed together that workers were essentially sleeping next to each other.
105. Workers told Signal personnel on numerous occasions that they found these conditions to be intolerable. Internal communications among Signal personnel discussed the "overcrowding," acknowledging that the Pascagoula camp was at least "3 bunk-houses" shy of appropriate capacity, and that "more toilet/sink capacity" was needed.
Rotten Food 106. The food provided by Signal was deplorable. Meals were offered exclusively in a mess hall, which was only open during limited hours. Workers who showed up a few minutes late for a meal were denied food altogether. Those who did eat were often served rotten food and, at times, workers found bugs in their meals.
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107. Workers frequently complained to Signal personnel that the food was so bad that they were left hungry. Others complained to Signal that the food was making them physically ill.
108. In an email to other Signal personnel, Signal Senior Vice-President & General Manager Ron Schnoor acknowledged the "bad, stale, molded, and otherwise poor quality food."
Rampant Disease 109. Even apart from the kitchen conditions, the man camp itself was a breeding ground for bacteria and disease. 110. Workers frequently became severely ill. As explained by the Signal's manager of the Pascagoula man camp:
Our Indians have been dropping with sickness like flies.
[They1 are getting worried and believe there are unhealthful
conditions in the camp. It is true. The reason is because the plumbing was so shoddily done by GE's subcontractors, and water has leaked everywhere and stagnated as a result, which serves as a bacterial breeding ground.
Perpetual and Abusive Oversight Ill. Signal instilled in Plaintiffs a climate of fear through perpetual and invasive oversight and surveillance. 112. The Pascagoula man camp was located in an isolated industrial area that was miles removed from other residential communities, shopping facilities, worship houses, and other basic amenities. The man camp was enclosed by fences and accessible only by a single entrance, which was guarded by an armed security guard at all times. When returning "home" from work and entering the camp, Plaintiffs were required to show identification and subject themselves and their belongings to search. Their movements into and out of the camp were logged.
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113. Guests were not normally permitted in the man camp; Plaintiffs were permitted visitors in the parking lot.
114. Because the camp was isolated, Plaintiffs relied upon transportation from Signal to and from work and also to other populated areas. However, Signal would only take them to Wal-Mart or the bank. Even then, Plaintiffs had little privacy as Signal security would occasionally follow them into Wal-Mart.
115. Signal's private security forces entered the Plaintiffs' bunk area at night. Signal personnel and camp security guards conducted "surprise searches" of the bunkhouses, including searches of workers' personal belongings.
116. Plaintiffs were not told when these searches would be conducted (again, in what was supposed to be Plaintiffs' "home"), nor were they apprised of what it was Signal was looking for.
117. Signal prohibited Plaintiffs from drinking alcohol at the camp. Violation subjected the workers to fines of $250 and suspension from work. A second "offense" would result in a $500 fine; a third "offense," $750.
118. The prohibition of alcohol was modeled after Signal's policies for conduct in the workplace despite the fact that the workers were living, not working, in the man camp.
119. Signal did not bar its non-Indian workers from having visitors or drinking alcohol in their homes. Nor did Signal confine its non-Indian workers to crowded bunkhouses or subject them to invasive searches of their homes or belongings and near-constant surveillance.
Signal Charged Plaintiffs Approximately $1050 Each Month to Live in These Conditions 120. For the "privilege" of living in these conditions, the Indian workers (including
each Plaintiff) were charged $35 dollars per day (approximately $1,050 per month). From this
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amount, $21 was allocated towards rent and $14 towards food. The $35 daily fee was deducted automatically from the Plaintiffs' paychecks.
121. Pol personally received $1.50 per day per worker from the $14 food cost in pure profit for having referred a caterer, Laxmi Catering, to Signal. When Pol was later terminated by Signal, the $1.50 per worker per day profit was not remitted to the workers but was instead paid to another caterer, Anjay Keswani.
122. Before the $35 per day value was set, Signal's Senior Vice President and General Manager Ronald Schnoor initially recommended that Signal charge the workers $53.50 per day. Schnoor reached that figure by calculating the amount it would take to amortize over just ten months the entire cost Signal incurred building the man camps in Pascagoula, Mississippi, and Orange, Texas-a $7 million capital expenditure. Schnoor shockingly dismissed the devastating impact of this exorbitant $1,600 per month fee by cavalierly asserting the Plaintiffs and their fellow workers would all be "happy campers" because Signal's living arrangements and wages were likely to be an improvement over conditions in India.
123. After a short time in the camp, workers (including certain Plaintiffs) began complaining about the poor conditions and asked to live outside the camp in accommodations of their own choosing. In response, Signal informed Plaintiffs that if they tried to live outside the camps, Signal would continue to deduct $35 per day from their paychecks. Given their substantial debts, this wage deduction left Plaintiffs with no choice but to remain at the camp.
124. Signal did not require any non-Indian workers to pay for Signal's capital expenditures, nor did it require any other workers to pay for living expenses, whether or not they were living in Signal-provided housing.
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125. Signal imposed this onerous policy in order to avoid paying any of its own expenses. By exploiting the Plaintiffs' tenuous financial position, heavy debt load, precarious immigration situation and fear of job loss, Signal knew that they and their coworkers would have no choice but to continue working at the company. Indeed, because of the grip in which Signal held its Indian workers, the Plaintiffs felt compelled to remain at the Pascagoula man camp.
126. In contrast, workers of non-Indian race, ethnicity, or alienage were not required, or even allowed, to live in and/or pay for housing in the Pascagoula man camp.
Plaintiffs Experienced Other Discrimination by Signal and its Employees Due to their Race, Ethnicity, Religion, and Alienage
127. Defendants' racial animus and discrimination against Plaintiffs and the other Indian workers took other, equally abusive, forms.
128. Whether on "the Reservation" or at the worksite, Plaintiffs repeatedly heard Signal employees, including supervisors, use offensive and racist language in speaking or referring to Plaintiffs and the other Indian workers.
129. Management frequently referred to Indian workers by badge number, instead of attempting to pronounce their names.
130. In an April 5, 2007 email to Signal employees Bill Bingle and Tracey Binion, Signal employee Darrell Snyder stated his opinion that it was a "misguided notion that some of these Indians can be reasoned with," and discussed his plan to engage in a "rat hunt" in the Pascagoula camp to determine who was causing "dissension" among the workers.
131. Signal also displayed a shocking lack of respect for Plaintiffs' religious beliefs. 132. Signal knew that many of the workers were highly religious. In particular, Signal knew that certain of its workers were Sikh.
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133. Wearing a beard is an article offaith in Sikhism. In the Sikh tradition, a beard demonstrates a love of God and respect for the natural form God bestows on man.
134. Signal nevertheless demanded that Sikh workers shave their beards after arriving at the Pascagoula camp and threatened to deport them if they would not do so. When Plaintiff Ranjit Singh and other Sikhs were forced to shave their beards, they sat on the floor and cried, distraught. Workers of non-Indian race, ethnicity, or alienage and not of the Sikh religion were not subject to similar conditions of employment.
135. Signal also required Plaintiffs to engage in repeated "skills testing" evaluations that non-Indian workers were not required to take and subjected Plaintiffs to on-the-job discipline, periods without work, and unfavorable job assignments to which workers of nonIndian race, ethnicity, or alienage were not subjected.
136. Signal also forced Indian workers, including Plaintiffs, to work under conditions that were harder and more dangerous than the jobs Signal assigned to non-Indian workers. For instance, some worked in small, smoke-filled tanks that lacked ventilation, while non-Indian workers were not required to do the same. Plaintiff Jolmy Mathew fell from a scaffold and suffered chest pains, but Signal would not send him to a doctor or allow him to receive a medical exam.
137. When workers complained about these unsafe and illegal conditions, Signal demoted them, suspended them without pay, andlor threatened to deport them. Plaintiff Parshottam Mangani was demoted after complaining about slippery floors at his worksite, while other Indian workers who complained about unsafe conditions were suspended for three days for "safety violations." Workers of non-Indian race, ethnicity, or alienage were not treated this way.
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138. Defendants' discriminatory treatment of Plaintiffs and other Indian workers was motivated by racial, ethnic, and religious animus, as well as an animus against those ofIndian national origin.
Signal and the Agents Continued to Mislead the Plaintiffs About the Terms oftheir Employment
139. On numerous occasions during October, November, and December 2006, Burnett and Signal personnel met with workers who asked about the prospect of receiving green cards. During these meetings, Signal personnel were told by workers that the Agents and Signal personnel in India had promised that Signal would apply for and help the workers obtain green cards, and that the workers had paid as much as $25,000 for that opportunity.
140. Rather than tell the workers honestly that Signal had not applied for permanent residency on their behalf and had no present intention to do so, Signal continued to deceive the workers into believing that Signal would apply for and help them obtain permanent residency status. Notably, in or about January 2007, Dewan and Burnett traveled to the man camp and, with Signal employee John Sanders present, told Plaintiffs and other Indian workers that Signal would provide each Indian worker, including Plaintiffs, with a green card.
141. Beginning before this meeting and continuing throughout 2007, Signal employees communicated and consulted with each other and with the Agents concerning what to tell workers, including Plaintiffs, about the status of their visas and green card applications.
142. Signal also did nothing to address the fact that the Plaintiffs' temporary employment at Signal (which Signal itself represented to the U.S. Department of Homeland Security, under penalty of perjury, would be completed "within the...year") was not economically justifiable in light of the crushing amounts of debt Plaintiffs incurred and the mandatory $35 per day deduction for room and board.
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143. By at least October 2006, shortly after the first workers (including Plaintiffs) arrived in Pascagoula, Signal personnel learned that each worker had been required to pay well over the equivalent of $1 0,000 to Pol, Burnett, and Dewan.
144. In internal correspondence and conversation, Signal personnel (including Signal executives) concluded that these "recruitment fees" were excessive and a root cause of dissatisfaction and low morale among the Indian workers.
145. Nevertheless, Signal did effectively nothing to remedy the situation. 146. First, although Signal sent a letter to Dewan and Burnett requesting that they refund half of the fees that they had received, Signal did not terminate its relationship with Dewan or Burnett or impose any penalty or withhold any payment when those individuals refused to comply. In fact, Signal did nothing even after Burnett (i) asserted to Signal that Dewan had refunded the workers' money, and (ii) furnished affidavits signed by workers attesting to the "fact" that they never paid any fees, both claims that Signal itself considered plainly false. 147. Second, despite believing that the fees being charged were unreasonable and were generating problems, Signal never demanded that Dewan or Burnett cease collecting such fees from new recruits who were still in India. Indeed, Signal continued to hire workers, including certain Plaintiffs, through Dewan and Burnett after it learned of the unreasonable fees that they charged, effectively ratifying the conduct of its Agents. 148. Third, Signal did not itself refund the unreasonable fees charged by the Agents, nor did Signal offer any assistance to mitigate the cost or modify its contract with the Agents in which it had been agreed that neither Signal nor Global would shoulder any of the "recruitment fees" for its Indian workers.
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In an Attempt to Quell Rising Worker Dissatisfaction, Signal Sends Three Workers Back to India, One of Whom Attempts Suicide
149. By the spring of2007 (approximately 3-4 months after workers first arrived), it became increasingly clear that the conditions at the Pascagoula camp were intolerable. Workers began to consider ways to convince Signal to improve the conditions and sought outside advice from local church goers and attorneys.
150. In late February 2007, when Signal learned that certain workers had contacted a lawyer, Signal threatened to send the most vocal workers back to India.
151. Similarly, Dewan called one vocal worker's wife in India and warned her to tell her husband to stop making trouble at Signal.
152. News of Dewan's call to India spread among the workers, and substantially heightened Plaintiffs' fears that Defendants would retaliate, perhaps even with violence, against them and their families if they complained about or tried to leave the discriminatory and degrading conditions.
153. Signal escalated its pressure on the workers. In a meeting with the workers, including Plaintiffs, on March 8, 2007, Signal management told them that Signal would fight back against any "organizing" efforts, and that Signal would not extend any ofthe workers' H2B visas if a single worker took legal action against Signal.
154. On that same day, Signal decided to terminate and forcibly send back to India five of the ostensible "camp leaders," and to do so in a way that would make an example out of them and intimidate the other workers into remaining scared and compliant.
155. Early in the morning of March 9, 2007-when the workers for both the day and night shifts were present at the carnp-Signallocked the gate to the Pascagoula man camp, thereby blocking the only exit. At approximately the same time, Signal camp coordinator Darrell
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Snyder and five security guards swept through the bunkhouses carrying pictures of the men targeted for termination. Because Mr. Snyder and the security guards could not differentiate the appearance of these Indian men, they accosted numerous workers to determine whether they were the individuals shown in the pictures.
156. By 6:00 a.m., Signal had identified the five workers, taken them into "custody" in a side room, and told them that they were fired and would be deported. Distraught at what that meant for him and his family, one of the workers slashed his wrists and attempted suicide in front of Plaintiff Parshottam Mangani.
157. By early afternoon, local media, religious advocates, and other individuals had gathered outside the camp gates to express their concern over the attempted suicide and the forced detention of the other men.
158. The incidents of March 9, 2007 caused great fear in each of the Plaintiffs. Not only were they afraid ofthe worsening tension among the workers, they were scared of what Signal would do to them if they raised concerns about conditions at the camp. Plaintiffs believed, based on Signal's conduct, that protesting their plight would lead to arrest, imprisonment, bodily harm, and deportation back to India.
159. Indeed, by its conduct over March 8 and 9, 2007, Signal intentionally created a climate offear and intimidation in order to overawe the Plaintiffs and their coworkers into dropping their complaints about the camp and their treatment at the hands of Signal and its Agents.
Signal, Assisted by Burnett and Dewan, Used Fraudulent and Coercive Tactics to Keep Plaintiffs in the Pascagoula Camp
160. Following the March 9, 2007 incident, Signal used additional fraudulent and coercive tactics to keep the workers, including Plaintiffs, under its control.
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161. Later that month, Signal Senior Vice President Ron Schnoor addressed the entire Pascagoula man camp about what had happened on March 9.
162. Schnoor used two tactics: fraudulent promises of long-term employment, and threats to send the workers back to India.
163. First, Schnoor assured the men that Signal would continue to employ them for the "long term." That assurance was demonstrably false at the time, given that Signal still had not decided whether it would extend any of the workers beyond the initial ten-month visa period, and given that Signal had already begun to evaluate the Pascagoula workers and had decided to fire and not apply for visa extensions for certain workers.
164. Second, Schnoor threatened the men, telling them that if anyone Indian worker filed a lawsuit against Signal, Signal would refuse to extend any of the H-2B visas for any of the workers, and would therefore send all of them back to India. Signal knew full well that this threat would coerce the workers, including Plaintiffs, into staying at the camp, lest they return to India in crushing debt.
165. Nevertheless, even given the threats and false promises, by March 2008, over three-quarters of the Indian workers in the Pascagoula camp had escaped from Signal. Many were terminated; others left of their own accord due to the low pay, abusive treatment, and deplorable living conditions.
166. No Plaintiff received a green card. Indeed, neither Signal nor the Agents ever applied for a green card for any Plaintiff. Malvern Burnett Purported to Act as Attorney to Plaintiffs, but In Reality Was Working Solely
on BehalfofDefendants
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167. At all relevant times, Burnett had an attorney-client relationship with each Plaintiff and, indeed, each Indian worker employed by Signal, for purposes of immigration issues and each Plaintiffs' work for Signal.
168. Burnett prepared the immigration forms required for Plaintiffs to apply for H-2B status. In completing those forms, Burnett represented to the U.S. Department of Homeland Security, under penalty of perjury, that the Plaintiffs would stay in the United States only temporarily, returning to India "within the coming year." At the same time Burnett was submitting those forms, he was affumatively telling the workers, including Plaintiffs, that they would be eligible for permanent residency, and that he would assist them in applying for green cards.
169. Further, Burnett learned that, after they arrived in the United States, the workers, including Plaintiffs, asked Signal personnel when they could expect to receive green cards. After learning this, Burnett did nothing to correct his clients' misimpression.
170. To further his deception, Burnett concealed from Plaintiffs where his true loyalties lay. As noted above, by mid-2006 Burnett had entered into an attorney-client relationship with Signal for the broad purpose of applying for and obtaining lawful status for Indian workers to come to the United States. Later, in 2007, Signal and Burnett entered into a written Retainer Agreement memorializing the arrangement as it had been operating-namely that Burnett would "represent you [Signal] in the matter of H-2B Visa extensions for MS and TX" on immigration matters at zero cost while the fees for his work on behalf of Signal were to be taken from the Indian workers, including Plaintiffs.
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171. Burnett never disclosed his attorney-client relationship or payment arrangement with Signal to the Indian workers, including Plaintiffs, much less received their waiver of the conflict of interest it caused.
172. Burnett also entered into an attorney-client relationship with Dewan and Pol, starting no later than mid-2006. Burnett never disclosed this attorney-client relationship with Pol and Dewan to the Indian workers, including Plaintiffs, much less received their approval for it.
173. Burnett also had a "Multilateral Business Agreement" with Dewan and Pol, for the broad purpose ofrecruiting Indian workers to come to the United States. Burnett never disclosed this "Multilateral Business Agreement" to the Indian workers, including Plaintiffs, much less received their approval for it.
174. One incident in particular crystalizes the contempt with which Burnett viewed his Indian clients. On December 16, 2006, Burnett sent an email to Dewan and Pol regarding Pravin Kumar N. Patel, a Signal worker and client of Burnett. Patel had stopped payment on a check to Burnett. Burnett told Dewan and Pol to ensure that "the idiot" Patel restore the payment and threatened to have Patel's visa "mysteriously" revoked if Patel did not pay. Later in the email, Burnett referred to all the Indian workers, who were his clients, as "the idiots" and speculated about whether he should threaten them with "immediate deportation" in order to prevent them from stopping payment on future checks.
175. Burnett also forwarded emails he received from his Indian worker clients to Dewan. Burnett forwarded these attorney-client protected communications without permission from his clients, the workers.
176. Such appalling behavior violates not only the Mississippi Rules of Professional Conduct for attorneys, but basic notions of loyalty, propriety, and honesty.
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Plaintiffs Each Relied on the Defendants' Representations Lakshmanan Ponnayan Achari
177. In or about the last week of April 2006, Achari was working as a fitter in Chennai, India. A boy from Achari's hometown in Southern India called Achari and said that he had seen newspaper advertisements offering the opportunity to live in the United States and obtain a green card. Achari subscribed to one of those newspapers so he looked at the advertisement and confirmed that it promised the opportunity to get a green card.
178. Achari then spoke with a friend, who had been working with Dewan Consultants. The friend knew the personal phone number of a man named Salimon and called Salimon on behalf of Achari. Salimon said that Achari should come to an interview.
179. In or about May of2006, Achari traveled with a friend to the friend's interview with Dewan Consultants. Achari spoke directly with Salimon, who told Achari that there were job openings for fitters in the United States. Achari told Salimon that he did not have a passport, but Salimon assured him that this would not be a problem.
180. On Salimon's recommendation, Achari took a written test for the fitter job. Salimon, Dewan, Pol, and, on information and belief, Signal employees were present for the test. Pol reviewed the test results and informed Achari that he passed. Dewan also reviewed the test results and made notations on Achari's testing paperwork.
181. About two days later, Achari attended a group interview. At that interview, Salimon explained that Achari could obtain a green card. Salimon also told Achari that this process would cost 600,000 rupees (approximately $11,000).1
Unless otherwise specified, all U.S. dollar approximations are determined through the use of a historical exchange rate calculator, available at http://www.oanda.com/convert/fxhistory.
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182. Achari paid this amount to Salimon, Dewan, Burnett, and Pol in three installments in or about and between June and December of2006. To raise this money, Achari sold his wife's jewelry. He also incurred substantial debt; he obtained two loans, each at a 36 percent interest rate.
183. In or about November of 2006, Achari met with Dewan and, on information an] belief, a Signal employee. Achari told Dewan that he had recently heard from other workers mat they were receiving H-2B visas and that this was the first time Achari heard that he might receive anything besides a green card. Dewan assured Achari that Achari had paid for and would receive a green card.
184. Also in or about November of 2006, Achari again met with Salimon. Salimon assured Achari that he would receive a green card within eight months.
185. On the day he was scheduled to fly to the United States, Achari traveled to Dewan's office in India to obtain his passport. Although Achari arrived in the morning, DeViID did not meet with him until the evening - just two hours before his flight was scheduled to depart. Dewan demanded that Achari sign blank pieces of paper and pay the final installment of his "recruitment fees" before Dewan would give him his passport. Achari felt intimidated and that he had no choice but to comply. He signed and left for the airport.
186. After arriving in the United States, Achari felt compelled to remain at Signal's man camp and work for Signal because, among other reasons, Signal would deduct living expenses from his paycheck even if he lived elsewhere. Defendants also continued to assure Achari that he would receive a green card. For instance, shortly after he arrived in Pascagoula, Achari met with Burnett and Snyder. At that meeting, Burnett assured Achari that he had
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applied for H-2B visa extensions for him. Achari also met with Pol, Burnett, and Snyder. At that meeting, Burnett told that Achari that his green card would be processed.
187. Achari relied upon Defendants' promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants' "recruitment fees," his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would take adverse immigration action against him, Achari felt intimidated into acquiescence and compelled to continue working for Signal.
Kodakeril Baby Biji 188. In or about July 2006, Biji saw a newspaper advertisement offering the chance to obtain an H-2B visa and then permanent residency in the United States. In response, he called Dewan Consultants, and Salimon told Biji that he should attend an interview that would take place about one month later. 189. Salimon, Dewan, and two Signal employees were present at Biji's initial interview. The Signal employees gave Biji a written test, and Salimon explained that Biji and the other attendees would obtain a ten month H-2B visa and then a green card. Salimon also explained that this process would cost over 600,000 rupees (approximately $12,500). This money would be paid to Dewan Consultants, Pol, and Burnett. 190. Biji paid the fees demanded by the Agents. To raise the money, he used his savings and borrowed from a bank at an interest rate of approximately 10 to 13 percent annually. Biji borrowed other funds at a 20 percent annual interest rate. 191. Approximately one or two months after his initial interview, Biji brought a fee installment to Dewan and Burnett at a hotel in India. Burnett told Biji that he would receive a
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visa and gave Biji paperwork promising an H-2B visa and permanent residency. Then, on or about November 7, 2006, Biji met again with Salimon, who stated that Biji would travel to the United States for ten months on an H-2B visa, return to India, and then come back to the United States with a green card.
192. Just before Biji left India, Dewan forced him to sign paperwork written in English. Because Biji did not speak or read English, he could not understand what the paperwork said.
193. After arriving in the United States in or about December 2006, Biji met with Burnett and Sanders at the Pascagoula camp. Biji asked both Burnett and Sanders when he would receive his green card. Both assured him that Signal would file for his green card.
194. Biji relied upon Defendants' promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants' "recruitment fees," his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would take adverse immigration action against him, Biji felt intimidated into acquiescence and compelled to continue working for Signal.
Xavier Disoliyan 195. In or about June 2006, Disoliyan was working as a welder in Abu Dhabi and saw an advertisement in a local newspaper promising an opportunity to work for a "leading" United States marine company that would provide work visas and permanent residency. In or about July 2006, Disoliyan attended a walk-in skills test in India, at which Dewan, Salimon, and Signal representatives were present. At the skills test, Dewan and Salimon told Disoliyan and other workers that they would travel to the United States on H-2B visas. Dewan and Salimon also said
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that, after six months, the workers would receive green cards and would be able to bring their families to the United States.
196. Dewan and his agents told Disoliyan and others that they would need to pay over 700,000 rupees (approximately $14,436) for this opportunity. DisoJiyan spoke privately with Dewan and Salimon and told them that he did not have enough money. Dewan and Salimon explained that Disoliyan could pay in installments, and he should take advantage of the opportunity because the job in the United Sates would allow him to save 150,000 rupees (approximately $3,000) every month. Based on Dewan's and Salimon's assurances, Disoliyan believed that he would be able to pay back any loans in as few as six months.
197. Disoliyan paid the fees demanded by Dewan, Pol, and Burnett by using family property as collateral for loans. He secured a loan for approximately 300,000 rupees by posting the house that he had built and the property he had received as part of his wife's dowry as collateral. Disoliyan borrowed the remaining 400,000 rupees (approximately $8,200) through a loan against which his brother-in-law offered his own house as collateral. Pursuant to the terms of this loan, Disoliyan was required to begin repaying the principal within one month, and a default would mean foreclosure on his brother-in-Iaw's home.
198. In or about August 2006, Disoliyan met with Dewan, Salimon, and Burnett to pay for what Burnett said was his permanent residency visa. At this meeting, Burnett assured Disoliyan that his permanent residency application would be granted.
199. In or about November 2006, Disoliyan traveled to Dewan's office in Mumbai to pay his final fee installment and receive his plane ticket and passport. It was there that he first learned that Signal would charge him $35 per day for food and accommodations. Disoliyan was upset about this additional cost and concerned that it would make it more difficult for him to
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repay his loans. Dewan assured Disoliyan he would be able to send 150,000 rupees (approximately $3000) back to India each month. Regardless, Disoliyan decided that he had no choice but to agree because Dewan and his associates told him that if he refused, he would not receive a refund of the fees that he had already paid. Dewan also pressured Disoliyan to sign additional paperwork without giving him an opportunity to read it because they were in a rush to get to the airport.
200. Upon arrival in the United States, Disoliyan felt that Signal's work conditions were unsafe. He did not express those concerns to Signal management, however, because he observed that Signal demoted, fired, suspended, or reduced the pay ofIndian workers who complained about the conditions. At times, Disoliyan was unable to send enough money home to pay his loans because of the charges Signal deducted from his paycheck.
201. Disoliyan relied upon Defendants' promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants' "recruitment fees," his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would take adverse immigration action against him, Disoliyan felt intimidated into acquiescence and compelled to continue working for Signal.
Rajankunju Geevarghese 202. In or about April 2006, Geevarghese saw an advertisement in an Indian newspaper that offered jobs in the United States for pipefitters and welders. The advertisement also stated that workers would receive work visas and green cards. Geevarghese called Dewan Consultants and was told to attend one of a series of meetings scheduled for early May.
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203. On or about May 2 or 3, 2006, Geevarghese attended a meeting at the Trident Hotel in Cochin, at which Dewan, Pol, and Salimon were present. Upon information and belief, Signal staff members were also present. During the meeting, Dewan said that the workers woud initially receive H-2B visas, which would be extended for nine additional months. At the saml time that the workers were processed for H-2B visas, Signal would also apply for green cards fur every worker. Dewan also stated that the cost for the entire process would be 700,000 rupees (approximately $15,630), which would be paid in three installments to Pol, Burnett, and Dewall. At Dewan's request, Geevarghese and other interested workers signed a "temporary contract," which documented what was discussed at the meeting, including the fees and the promise of a visa and a green card.
204. Approximately three days later, Geevarghese received a call from Salimon, wiJo told him to attend a welding test on or about May 8, 2006. Geevarghese took two tests administered by two Signal employees. Salimon then informed him that he had passed and should begin to collect the money needed for his fees.
205. Although Dewan had initially told Geevarghese that the process would cost 700,000 rupees, the Agents ended up demanding even more from Geevarghese, which Geevarghese paid. In order to raise the money necessary to pay the fees, Geevarghese depleted his savings and sold his wife's and his children's jewelry. In addition, he took out one loan for 250,000 rupees (approximately $5,582) and another loan for 450,000 rupees (approximately $10,102), both at 24 percent annual interest.
206. Following his skills tests, Salimon called Geevarghese regularly to provide him with updates concerning the status of his case and to inform him when and where to pay the fee
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installments. Geevarghese paid these fee installments to Dewan, Pol, and Burnett in or about May tbrough November 2006.
207. On or about November 6, Geevarghese met with Dewan, Salimon, and Sanders, who told him not to mention the fees he had paid to Dewan, Pol, and Burnett during his interview at the United States Consulate.
208. On or about November 24, 2006, Salimon arranged for Geevarghese to fly from Cochin to Mumbai so that he could make his final payment and receive his passport and plane ticket to the United States. When Geevarghese met with Dewan that day, Dewan insisted that Geevarghese pay an additional 4,000 rupees (approximately $90) for the plane ticket to Mumbai. Geevarghese had not been told about this fee and only had 6,000 rupees left for travel expenses. Dewan, however, refused to give Geevarghese his passport and ticket to the United States until he paid the 4,000 rupees. Intimidated by Dewan, afraid of being stranded in Mumbai, and fearful of losing the opportunity to work in the United States, Geevarghese paid Dewan. Dewan then demanded that Geevarghese sign several contracts without offering him enough time to review them.
209. In the United States, Geevarghese was shocked by the living conditions he was forced to endure. He also learned for the first time that Signal would deduct money from his paycheck for the tools he used. Nonetheless, Geevarghese was afraid to leave his position at Signal and return to India; he had sold everything of value that his family owned and knew he would never be able to pay back his enormous debts working in India.
210. Geevarghese relied upon Defendants' promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence ofsuch falsehoods. Based on his fear of mistreatment and abuse by
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Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants' "recruitment fees," his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would take adverse immigration action against him, Geevarghese felt intimidated into acquiescence and compelled to continue working for Signal.
Jomon George 211. In or about April or May 2006, J. George saw an advertisement in an Indian newspaper for pipefitting jobs in the United States. The advertisement stated that permanent residency status would be available to workers after six to nine months. 1. George called the listed number and spoke with Salimon, who told him about an interview and informational seminar. Salimon and Dewan were present at the seminar, as were two or three men from Signal. Salimon explained that in order to obtain their green cards, the workers would need to pay Dewan, Pol, and Burnett 600,000 rupees (approximately $13,400). 212. J. George later took and passed a qualifying test. After the test, a Signal representative assured 1. George that he would receive permanent residency status ifhe accepted the job with Signal. J. George then signed an agreement with Signal, which he understood to promise him a 10-month H-2B visa that would be extended and then converted into a green card. 213. In or about August 2006, 1. George met with Burnett and Dewan, who promised him that the workers would receive green cards that would enable them to live and work permanently in the United States. 214. George paid the substantial fees demanded by Dewan, Pol, and Burnett in installments in or about August through November 2006. In order to raise this money, J. George took out a loan at 18 percent annual interest, using a piece of land that his wife owned as collateral. He also sold all of his wife'sjeweJry and borrowed money from his brother and several friends.
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215. Before flying to the United States, 1. George traveled to Dewan's Mumbai office to collect his passport and plane ticket and pay his final installment. 1. George asked Dewan if he could get his money back if he did not want to go to the United States, but Dewan told him "no." Dewan's agents required J. George to sign various documents, but because the documents were in English and the agents rushed him, J. George did not have an opportunity to read or understand what he was signing.
216. In the United States, J. George and the other Indian workers were told by Sanders and other Signal officials that if they caused any trouble, they would be sent back to India. J. George believed that he had no choice but to endure the unsanitary and unsafe conditions without complaint because Signal controlled his immigration status. He did not want to jeopardize his employment with Signal because he needed to earn enough money to payoff the debt he had incurred in order to pay Dewan, Pol, and Burnett.
217. J. George relied upon Defendants' promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants' "recruitment fees," his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would take adverse immigration action against him, J. George felt intimidated into acquiescence and compelled to continue working for Signal.
Shaiju Vadakkal George 218. In or about April 2006, S. George had been working as a welder in Oman for nine years when he learned from a friend about an advertisement for welding jobs and permanent residency in the United States. After calling Dewan Consultants and speaking with Salimon, S. George took emergency leave from his job to attend a seminar in India led by Dewan, Salimon,
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and Burnett. At the seminar, Burnett explained that the workers would travel to the United States on H-2B visas, which would be extended twice. They would then receive green cards and be able to bring their families to the United States permanently. Dewan explained that green card processing would cost 550,000 rupees (approximately $12,280), and H-2B processing would cost 200,000 rupees (approximately $4,460).
219. Approximately one month later, S. George received a call from Salimon, who explained that the fee had been reduced to 600,000 rupees (approximately $13,070). S. George said that he wanted to wait for a green card rather than start with an H-2B visa, but Salimon convinced him to start work on just an H-2B visa. Shortly after this conversation, S. George completed a skills test administered by Salimon and several Signal employees. After a Signal employee told George that he passed the test, Salimon instructed S. George to begin collecting money for his first payment.
220. S. George paid the 600,000 rupees demanded by the Agents by borrowing money at an interest rate of approximately 5 percent per month. He secured a second loan using his wife's jewelry as collateral. Just before his consular interview, S. George resigned from his job in Oman.
221. On or about November 28, 2006, S. George traveled to Dewan's office to pay his final fee installment and receive his ticket and passport. Dewan refused to give S. George his ticket and passport, however, because Dewan claimed that he owed an additional 10,000 rupees. S. George knew that ifhe failed to pay the 10,000 rupees, he would forfeit all of the money that he had already paid to Dewan, Pol, and Burnett. S. George also felt compelled to pay because he had already quit his job in Oman and he could not make enough money in India to repay his debts. He begged some friends who were also at Dewan's office to help him, and together, they
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were able to raise 10,000 rupees. After S. George paid his final fees, Dewan would not give him his ticket and passport until he had relinquished all of the receipts and documents that he had received in connection with his recruitment.
222. After S. George arrived in the United States, he attended a meeting at which Burnett, Dewan, and a Signal representative all warned the Indian workers not to criticize Signal ifthey wanted to obtain green cards.
223. S. George relied upon Defendants' promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants' "recruitment fees," his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would take adverse immigration action against him, S. George felt intimidated into acquiescence and compelled to continue working for Signal.
Mouleswararao Guntamukkala 224. On or about May 23, 2006, Guntamukkala read a newspaper advertisement placed by Dewan Consultants. The advertisement offered the opportunity to work in the United States and obtain a green card. That same day, Guntamukkala spoke with a representative of Dewan Consultants, who told him that he could obtain an H-2B visa, which would be converted to a green card ifhe worked at Signal for one year. 225. Approximately one week later, Guntamukkala attended a small meeting at the office of Dewan Consultants, where Dewan explained the process in similar terms. Dewan also stated that it would cost each worker the equivalent of approximately $20,000. Shortly after the meeting, Guntamukkala took and passed a welding test, at which Dewan, Pol, and a Signal
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employee were present. Dewan and Pol gave Guntamukkala a signed statement promising that he would receive a green card if he passed his welding test and worked at Signal.
226. In order to raise the money to pay Dewan, Pol, and Burnett, Guntamukkala borrowed the equivalent of approximately $7,000 from a neighbor at approximately 3 percent interest per month. He also borrowed approximately $12,000 from his closest friend at 2 percent interest per month and sold his home - the only property he owned - to repay his friend. Guntamukkala borrowed the remainder of the fees from his family. Guntamukkala paid all of the fee installments that the Agents demanded between June and November 2006. Dewan Consultants withheld his passport until he paid this money.
227. After arriving in the United States, Guntamukkala asked a Signal employee when he would obtain his green card. The employee told Guntamukkala that the green card paperwork was being processed slowly due to the large number of people who would be obtaining green cards. He told Guntamukkala not to worry, however, and assured him that he would receive a green card.
228. Despite the dangerous and difficult work conditions at Signal, Guntamukkala was afraid to complain. When he told a supervisor that Signal was pushing him to work too hard, the supervisor told him that Signal would send him back to India if he complained again.
229. Guntamukkala relied upon Defendants' promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants' "recruitment fees," his fear that Signal would confiscate even more of his hard-earned wages,
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and his fear that Signal or Burnett would take adverse immigration action against him, Guntamukkala felt intimidated into acquiescence and compelled to continue working for Signal.
Joy Jacob 230. Jacob was recruited in or about 2006. 231. During meetings with Dewan and Burnett in India in or about mid-2006, Dewan and Burnett made numerous representations that led Jacob to believe that in exchange for paying thousands of dollars in "recruitment fees," Signal and the Agents would assist Jacob with applying for and receiving pennanent residency in the United States. 232. In reliance on these promises, Jacob incurred substantial debt and paid thousands of dollars in "recruitment fees" to Dewan, Burnett, and Pol. 233. After arriving in the United States, Jacob felt compelled to remain at Signal's man camp and work for Signal because, among other reasons, Signal would deduct living expenses from his paycheck even ifhe lived elsewhere, his H-2B visa did not pennit him to work for another U.S. employer, Signal constantly monitored him and other workers and threatened to deport them if they complained about the horrible conditions at Signal, and he believed that he would face financial ruin and bankruptcy if he returned to India. 234. Jacob relied upon Defendants' promises of pennanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants' "recruitment fees," his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would institute adverse immigration action against him, Jacob felt intimidated into acquiescence and compelled to continue working for Signal.
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Biju John 235. In or about April or May of2006, John read an advertisement in an Indian newspaper for a job in the United States that would pay $144 per day and promised H-2B work visas or green cards. John called Dewan Consultants and spoke with a representative of the company. The representative told John that Malvern Burnett would obtain a green card for him and that the process would cost 650,000 rupees (approximately $14,515). 236. John attended a seminar in or about May 2006, where he met Dewan, Salimon, Pol, Burnett, and Sanders. They confirmed that John would need to pay 650,000 rupees in "recruitment fees." They also told John that ifhe paid Burnett an additional $4,000, he could work anywhere in the United States. 237. John paid Dewan, Pol, and Burnett 650,000 rupees in three installments. John also paid an additional 400,000 rupees (approximately $8,350) in travel and other expenses related to this process, resulting in a total cost of 1,050,000 rupees (approximately $22,865).
238. John raised the money for these expenses and fees by selling a piece of property that he owned, borrowing money from his brother, and borrowing money that his father raised by selling land and other items. He also borrowed 150,000 rupees (approximately $3,130) at 5 percent monthly interest.
239. On or about November 19,2006, John traveled to Dewan's Mumbai office to collect his passport and plane ticket to the United States. Shortly before John left to catch his flight, Dewan gave him a "service agreement" document and told him to sign it immediately. Dewan told John that he could not board the plane until he signed the agreement. Dewan also said that if John missed his flight, he could not recover the money he had paid. Because his flight was about to leave, John quickly signed the agreement without reading it. When Dewan
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gave John his passport and plane ticket, John learned he had paid twice the value of the plane ticket.
240. After arriving in the United States, John felt compelled to remain at Signal's man camp because Signal would deduct living expenses from his paycheck even if he lived elsewhere. He was afraid to complain about the conditions at Signal because Signal threatened to send John and other workers back to India if they misbehaved or spoke to others about Signal's actions. He felt that he could not leave his job at Signal because he needed to make enough money to repay the loans that he had borrowed from his family.
241. John relied upon Defendants' promises ofperrnanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants' "recruitment fees," his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would take adverse immigration action against him, John felt intimidated into acquiescence and compelled to continue working for Signal.
Shibu Joseph 242. In or about April 2006, Joseph read a newspaper advertisement offering the opportunity for pipe fitters to work in the United States and obtain green cards. He spoke with a representative of Dewan Consultants, who invited Joseph to attend a seminar in May to learn more about the opportunity. 243. On or about May 2, 2006, Joseph attended a seminar at which Pol, Burnett, Dewan, and Salimon were present. Either Pol or Burnett (Joseph is uncertain of which) explained that workers would travel to the United States on H-2B visas, which would be extended for 18 to 24 months while their green card applications were processed. After they
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received green cards, the workers would be able to bring their families to the United States. Dewan explained that this process would cost a total of 600,300 rupees (approximately $11,000) to be paid in installments to Burnett, Pol, and Dewan. Joseph called Salimon after the seminar, and Salimon confirmed that workers would receive H-2B visas and green cards.
244. In or about May 2006, Joseph took a written exam administered by a Signal official. Salimon and Dewan were also present, and Salimon again assured Joseph that those who were hired would travel to the United States on H-2B visas while their green cards were being processed.
245. To pay his "recruitment fees," Joseph posted his wife's jewelry as collateral for a loan, and borrowed additional money from his brother, a friend, and his wife's family. Joseph also borrowed money from an acquaintance at approximately 3 percent interest per month. Joseph paid his first and second fee installments in or about August and November 2006, respectively.
246. On the day of his flight to the United States, Joseph traveled to Dewan's office in Mumbai and paid his final fee installment. At Dewan's office, either Dewan's assistant or his brother took all of Joseph's receipts and paperwork relating to his recruitment. Joseph feared that if he refused to give up his paperwork, he would lose the money he had paid. Dewan then demanded that Joseph quickly sign a number of papers, and said that he would not give Joseph his passport if he refused. Afraid that he would lose all of the money he had already paid and the opportunity to work in the United States, Joseph signed the papers without having a chance to read what they said.
247. At Signal, Joseph asked permission to live outside the man camp, but Sanders told him that the costs for room and board would be deducted from his wages even if he did not live
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there. Because he could not repay his loans ifhe also paid room and board both to Signal and outside the man camp, Joseph felt that he had no choice but to remain at the camp. He felt compelled to continue to work for Signal because it was the only way that he could repay his debts and keep his family from being cast into poverty.
248. Joseph relied upon Defendants' promises of permanent residency and good working conditions and would not bave sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants' "recruitment fees," his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would take adverse immigration action against him, Joseph felt intimidated into acquiescence and compelled to continue working for Signal.
Sunilkumar Maroittikal Kuttan 249. In or about Mayor June of2006, Kuttan read a newspaper advertisement offering the opportunity to work in the United States and obtain an H-2B visa and green card. The advertisement listed the contact information for Dewan Consultants. A few days after seeing the advertisement, Kuttan attended a large meeting, where Salimon, Dewan, Burnett, and Sanders were present. Dewan and Salimon explained that Kuttan and other Indian workers would travel to the United States and work at Signal for eleven months while their green cards were processed. Afterwards, they would return to India for a very short time after which they could come back to the United States with their families. 250. In or about Mayor June of2006, Kuttan met with Sanders and another American to take a welding test.
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251. Kuttan ultimately paid Dewan, Pol, and Burnett approximately 800,000 rupees (approximately $14,700). To pay these fees, Kuttan sold his wife's wedding jewelry, borrowed money from his family, and took out a loan at 18 percent interest.
252. In or about December of2006, Kuttan traveled to Dewan's office to collect his plane ticket and passport. Dewan required Kuttan to sign some documents before receiving his ticket and passport. Because Dewan rushed him, Kuttan did not have time to read the documents or understand what he had signed.
253. Kuttan relied upon Defendants' promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants' "recruitment fees," his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would take adverse immigration action against him, Kuttan felt intimidated into acquiescence and compelled to continue working for Signal.
Parshottam Ramchandra Mangani 254. In or about and between April and July 2006, Mangani read a newspaper advertisement for a job that offered permanent residency in the United States. 255. In or about the summer of2006, Mangani attended a seminar in New Delhi, where Dewan and an American gave a presentation about a job opportunity. They explained that Mangani and other workers would travel to the United States on H-2B visas, which would then be converted into green cards. Dewan then distributed documents which stated that the process would cost 700,000 rupees (approximately $15,155). 256. Mangani paid Dewan, Burnett, and Pol these "recruitment fees" in installments in or about and between July and November of2006. To raise the money to pay these fees,
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Mangani sold a 2 acre farm that had provided much of his family's income. He also sold a residential property he owned with a relative. After these sales, the only property his family owned was his father's house, where Mangani and his mother, wife, and daughter also lived.
257. Just before he flew to the United States, Mangani traveled to the office of Dewan's agent. An employee demanded that Mangani sign paperwork. Mangani asked ifhe could read the paperwork, but the employee insisted that Mangani's flight to the United States would leave soon, and there was no time to read the paperwork. Mangani felt that he had no choice but to sign. Only then did Mangani receive his passport.
258. After Mangani arrived in the United States, Signal required him to sign paperwork agreeing that Signal could deduct $245 per week from his paycheck for food and housing. When Mangani and other workers asked if they could live outside of the man camp, Signal employees said that they had to remain at the camp. Signal also required Mangani to sign paperwork under which he agreed to pay for the tools that he used. Because the Signal employees threatened to send him back to India if he would not agree to this condition, Mangani signed the paperwork.
259. Mangani had been told by Dewan, Burnett, and Pol that he would earn the equivalent of200,000 to 300,000 rupees (approximately $4,300 to $6,462) per month at Signal. Based on these assurances, he had expected that he would be able to repay his debts and repurchase his land. Only after signing the paperwork allowing Signal to deduct hundreds of dollars per week from his salary did Mangani realize how difficult it would be to realize these goals.
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260. On multiple occasions, Mangani observed Signal personnel threaten to suspend or deport workers who complained about the conditions at Signal. As a result, Mangani felt compelled to work quietly and without complaint.
261. Mangani relied upon Defendants' promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants' "recruitment fees," his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would take adverse immigration action against him, Mangani felt intimidated into acquiescence and compelled to continue working for Signal.
Prakash Moses Kanagiah Manonmoni 262. In or about June 2006, Manonmoni saw an advertisement in an Indian newspaper announcing a program under which pipefitters could work in the United States and receive green cards. Manonmoni called the number in the advertisement and spoke to Salimon, who told him to attend an informational meeting in August 2006. 263. At this meeting, Salimon explained that Signal would process permanent residency visas for the workers. He stated that each worker would have to pay 850,000 rupees (approximately $18,700) plus airfare to the United States. Salimon asked interested workers to sign a contract at the meeting, and said that they would be contacted about a test and an interview. Manonmoni handed his signed contract to Dewan. 264. Later that month, Manonmoni was invited to an interview attended by Salimon, Dewan, Pol, and a Signal project manager. During this meeting, he also took and passed a written pipefitters' examination.
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265. Manonmoni ultimately paid Dewan, Pol, and Burnett 600,000 rupees (approximately $16,940). In order to pay these fees, Manonmoni sold a parcel ofland that he owned. He also took out two loans using his wife's jewelry and his life insurance policy as collateral.
266. Just before Manonmoni flew to the United States, he traveled to Dewan's office and paid his final payment. That day, Dewan assured Manonmoni that if he followed Signal's rules, Manonmoni would receive a green card.
267. When Manonmoni arrived in the United States, he was told that Signal would deduct $245 a week from his salary for accommodations, regardless of whether he lived at the man camp. Because he could not afford to repay his loans and pay room and board twice, he felt that he had no choice but to live at the camp.
268. Manonmoni relied upon Defendants' promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants' "recruitment fees," his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would take adverse immigration action against him, Manonmoni felt intimidated into acquiescence and compelled to continue working for Signal.
Adharsan Manuel 269. In or about June 2006, Manuel saw an advertisement in an Indian newspaper offering positions for welders in the United States and the opportunity to receive a green card. Manuel called the number listed in the advertisement and spoke with Salimon, who told him to attend a meeting at a hotel.
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270. During this meeting, at which Dewan, Salimon, and Pol were present, Dewan told Manuel and other prospective workers that they would travel to the United States on H-2B visas to work at Signal. Shortly thereafter, Manuel met with Dewan at his office, where Dewan explained that Manuel would also be able to receive a green card if he took the job at Signal.
271. On or about November 7, 2007, Manuel met with Salimon, Dewan, and Burnett to discuss his upcoming interview at the United States Consulate. They instructed Manuel not to mention Signal's promise that he would receive a green card during his consular interview, though Dewan and Burnett assured him that it would be taken care of once he arrived in the United States.
272. Manuel paid approximately 700,000 rupees (approximately $15,000) to Dewan, Pol, and Burnett for the opportunity to work for Signal. In order to raise this money, Manuel depleted his savings and secured a loan by offering his sister'S and wife's dowries as collateral.
273. After he arrived in the United States, Manuel learned for the first time that he had to pay $35 per day for accommodations that were much worse than any he had ever experienced.
274. Despite the squalid living conditions and the unsafe work environment, Manuel felt compelled to remain at Signal. He knew that ifhe left, he would be sent back to India and would not receive the green card he had been promised. Manuel believed that remaining at Signal was the only option that would allow him to repay his substantial debt; he knew that he could never make enough money to repay that debt in India. Manuel also felt compelled to remain because of Signal's conduct. Signal foremen constantly monitored Manuel- even when he went to the bathroom - and threatened to notify the police and immigration officials if Manuel left Signal. Signal employee John Sanders threatened to send Manuel and other workers back to India if they complained about the conditions at the man camp. Manuel also feared that Signal
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employees might retaliate against his family if he left or complained about the horrible conditions.
275. Manuel relied upon Defendants' promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants' "recruitment fees," his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would take adverse immigration action against him, Manuel felt intimidated into acquiescence and compelled to continue working for Signal.
Jacob Mazhukkattu Mathew 276. In or about June 2006, J.M. Mathew read a newspaper advertisement offering temporary and permanent work visas and employment with a marine company in Mississippi and Texas. He called Dewan Consultants and spoke with Salimon, who invited him to a meeting at a hotel. 277. Approximately one week later, 1.M. Mathew attended the meeting, where Dewan, Salimon, and Burnett were present. At this meeting, Burnett said that the workers would travel to the United States on H-2B visas. The workers would receive green cards after the H-2B visas had been extended. Dewan explained that this process would cost 600,000 rupees (approximately $13,000). After the presentation, lM. Mathew spoke separately with Burnett, who assured Mathew that his wife could also come to the United States after he received a green card. An employee of Dewan Consultants also assured J.M. Mathew that he could bring his wife and family to the United States after obtaining a green card, which the employee claimed would occur within two years.
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278. Soon thereafter, lM. Mathew took a skills test in the presence of Dewan, Salimon, and two Signal employees. The Signal employees supervised the test and told 1.M. Mathew that he had passed.
279. In order to raise the fees that 1.M. Mathew paid to Dewan, Pol, and Burnett, lM. Mathew's mother-in-law borrowed 125,000 rupees (approximately $2,693), posting her home and land as collateral. 1.M. Mathew mortgaged his home and land and borrowed the remainder at an interest rate of approximately 12 or 13 percent per year. 1.M. Mathew paid Agents three fee payments in or about and between August and November of2006.
280. In or about December 2006, 1.M. Mathew traveled to Dewan's office where he paid his final fee payment. There, he learned that Signal would deduct $35 per day from his paycheck for room and board. Although he believed that this amount was too high, he felt that he had no choice but to continue with the process because he had already paid Dewan, Burnett, and Pol a substantial amount of money that he could not recover.
281. In the United States, lM. Mathew remained at Signal because he continued to believe that he would receive a green card. He met regularly with Sanders and other Signal employees to discuss his immigration concerns. In addition, at a meeting held on or about March 8,2007, a Signal Vice President assured Mathew and other workers that they would receive green cards soon. 1.M. Mathew was afraid that ifhe returned to India, he would not be able to repay his debts and would lose his house and land, as well as his mother-in-Iaw's house and land.
282. 1.M. Mathew relied upon Defendants' promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants'
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"recruitment fees," his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would take adverse immigration action against him, J.M. Mathew felt intimidated into acquiescence and compelled to continue working for Signal.
Johny Mathew 283. In or about March 2006, J. Mathew saw a newspaper advertisement in India offering welding jobs in the United States and the possibility of receiving a green card. J. Mathew called Dewan Consultants in response to the advertisement. 284. In or about May 2006, J. Mathew attended a meeting led by Dewan, Pol, Burnett, and Salimon. At this meeting, Dewan explained that workers would travel to the United States on 10-to-ll month H-2B visas, which would be extended three times. During this time, Signal would apply for green cards for the workers. Dewan also stated that the workers would eventually be able to settle permanently with their families in the United States. Visa and green card processing would cost 750,000 rupees (approximately $16,750). 285. In or about Mayor June 2006, J. Mathew attended and passed a skills test, at which both Salimon and Dewan were present. 286. J. Mathew later met with Burnett, who reiterated that 1. Mathew would first receive an H-2B visa and would then get a green card. At this meeting, J. Mathew signed an agreement with Signal, which Salimon interpreted for him, and which J. Mathew believed to promise that he would receive a green card.
287. J. Mathew paid the "recruitment fees" that Dewan, Pol, and Burnett demanded in approximately three installments. In order to raise this money, J. Mathew sold his wife's wedding jewelry, used additional money that he had saved to buy a house, and took out a loan at 12 percent monthly interest. In or about the fall of2006, J. Mathew refused ajob in Kazakhstan so that he could stay in India and complete the necessary steps to receive his visa and green card.
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288. In or about late November 2006, a few days before his flight to the United States, J. Mathew traveled to Dewan's office. Dewan's staff forced him to sign several documents in a rushed manner and did not give him time to read or understand the documents. Dewan also demanded that J. Mathew return to Dewan his copy of the original signed agreement that promised him a green card, as well any receipts and papers related to the Signal opportunity. When J. Mathew hesitated, Dewan said that J. Mathew would not be able to go to the United States unless he returned the documents. Dewan refused to give J. Mathew his passport and plane ticket until he returned these documents to Dewan.
289. After arriving at Signal, J. Mathew learned that $35 would be deducted from his pay each day. Despite the reduced pay and terrible living and working conditions, J. Mathew felt trapped and unable to leave Signal. He was afraid that ifhe were sent back to India, he and his family would be thrust into poverty because of the debt he had incurred. He was also afraid that he would suffer mistreatment at the hands of Dewan and his associates.
290. J. Mathew relied upon Defendants' promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants' "recruitment fees," his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would take adverse immigration action against him, J. Mathew felt intimidated into acquiescence and compelled to continue working for Signal.
Nandhakumar Nagaraj 291. In or about Mayor June of2006, a friend of Nagaraj told him about a newspaper advertisement offering the opportunity to obtain an H-2B visa and green card. Nagaraj responded to the advertisement and called Salimon. Salimon confirmed that Nagaraj and other
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workers could obtain H-2B visas and green cards and told Nagaraj to attend a meeting in approximately three weeks to leam more.
292. Dewan, Salimon, Burnett, and Pol were present at this meeting. They explained that workers would travel to the United States on H-2B visas, and that during this time, Signal would process their green card applications.
293. Approximately one month after the meeting, Nagaraj took a welding test administered by an American. Approximately one month after the test, Nagaraj met with Salimon at a hotel. Salimon told Nagaraj that he could obtain an H-2B visa and work in the United States for ten months. After ten months, Nagaraj would automatically receive a green card and could bring his family to the United States.
294. Nagaraj ultimately paid Dewan, Pol, and Burnett 800,000 rupees (approximately $17,787) for this opportunity. Nagaraj borrowed approximately three-fourths of these fees at a monthly interest rate of 10 percent. He also depleted his savings and sold property and jewelry that his mother had received for her wedding from Nagaraj's grandfather.
295. Just before Nagaraj left for the United States, he traveled to Dewan's office in Mumbai. Dewan refused to give Nagaraj his passport until Nagaraj had paid the final installment and signed various documents. Nagaraj asked if he could read the documents, but Dewan refused and insisted that Nagaraj sign quickly so that he would not miss his flight to the United States.
296. After arriving in the United States, Nagaraj learned that Signal would deduct $245 from his paycheck each week for room and board. When he asked Signal employees ifhe could live outside the man camp, he was told that he was not permitted to live elsewhere. Nagaraj felt
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compelled to remain at Signal's man camp because he would not be able to repay his substantial debt if he was required to pay additional money for housing and food.
297. Nagaraj relied upon Defendants' promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants' "recruitment fees," his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would take adverse immigration action against him, Nagaraj felt intimidated into acquiescence and compelled to continue working for Signal.
Shaji Veluthalakuzhiyil Nanoo 298. In or about April or May of2006, Nanoo saw a newspaper advertisement placed by Dewan Consultants offering the opportunity for welders and pipefitters to work in the United States, and promising green cards and legal status for the workers and their families. Nanoo called the phone number listed in the advertisement and spoke to Salimon. Salimon said that the opportunity would include green card processing and that the process would cost 530,000 rupees (approximately $11,850). 299. In or about May 2006, Nanoo traveled to Cochin, India for an interview and skills test attended by Salimon and Dewan. At the interview, Salimon said that Signal would apply for Nanoo's green card once he arrived in the United States. Soon thereafter, at a meeting attended by Pol, Burnett, Dewan, and Salimon, Burnett also assured Nanoo that Signal would begin to process his green card once he arrived in the United States. 300. Nanoo faced considerable difficulties raising the money that he ultimately paid to Dewan, Pol, and Burnett. He mortgaged his land at approximately 12 percent interest and used jewelry belonging to his wife, sister, and sister-in-law as collateral for an additional loan. He
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also sold more family jewelry. Nonetheless, he was still unable to raise the total amount required.
301. Before he was scheduled to leave for the United States, Nanoo visited Dewan's office to pay his final fee installments and collect his ticket. Nanoo signed various documents, but because Dewan's assistants rushed him, he did not have a chance to read or understand what he was signing.
302. Before Nanoo was able to collect his ticket and passport, Dewan's assistants determined that Nanoo still owed a portion of his fees. Dewan refused to give Nanoo his passport until he had paid the remainder ofthe fees. Nanoo called his brother-in-law, who helped him raise some additional money. Only after Nanoo paid the full amount demanded by the Agents was he allowed to board the next flight to the United States.
303. In the United States, Nanoo learned that Signal would deduct $245 per week for food and housing from his paycheck, regardless of whether he lived in the man camp. Despite the terrible living conditions, the fees that Signal charged him made it prohibitively expensive to live elsewhere.
304. Nanoo's debt also made him feel compelled him to continue to endure the unsafe working conditions at Signal. Once, after Nanoo complained that the ships he worked on were unsafe, a Signal foreman suspended Nanoo for six days without pay. Nanoo knew that other Indian workers had experienced threats, retaliation, and deportation when they expressed their concerns about the conditions. Nanoo feared that if he were sent back to India, he would not be able to repay his debt, he would lose the land that he had mortgaged, and he and his family would become homeless. He was also worried that Dewan or his associates would hurt him or his family.
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305. Nanoo relied upon Defendants' promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants' "recruitment fees," his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would take adverse immigration action against him, Nanoo felt intimidated into acquiescence and compelled to continue working for Signal.
Mangalan Chandrasekharan Pillai 306. In or about June 2006, M. Pillai saw an advertisement in a Dubai newspaper offering the opportunity for pipefitters to work in the United States and receive green cards. The advertisement invited interested workers to attend a meeting at a Dubai hotel. 307. At this meeting, Dewan explained that Signal was looking for Indian workers to travel to the United States under H-2B visas to repair oil rigs. The H-2B visas would be renewed two to three times. After that, the workers would receive green cards and would be able to bring their families to the United States. Dewan also explained that workers would be required to pay Burnett, Pol, and Dewan visa and green card processing fees. 308. M. Pillai later took a skills test. When he was notified that he had passed, he returned to the hotel. There, Dewan gave him a letter stating that M. Pillai would receive an H2B visa and green card in exchange for processing fees. 309. M. Pillai ultimately paid approximately 600,000 rupees (approximately $\3,056) to Burnett, Pol, and Dewan. In order to raise this money, M. Pillai pawned his mother's and wife's jewelry and borrowed money from a friend. M. Pillai also took out two loans at 7 to 10 percent monthly interest, and an additional loan at 18 percent annual interest.
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310. In or about November 2006, M. Pillai traveled to Dewan's office to pay the final installments of his fees and receive his passport. After he gave the money to Dewan's brother, Dewan's associates rushed him out of the office before he could ask any questions or ask for a receipt.
311. After arriving in the United States, M. Pillai learned for the first time about the terrible living and working conditions and the substantial deduction that Signal took from each worker's paycheck for accommodations. M. Pillai did not complain about the living and working conditions, however, because he saw that Signal threatened to deport workers who "caused trouble." M. Pillai also feared that if he were sent back to India, he would be unable to repay his debts.
312. M. Pillai relied upon Defendants' promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants' "recruitment fees," his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would take adverse immigration action against him, M. Pillai felt intimidated into acquiescence and compelled to continue working for Signal.
Radhakrishna Pillai Sivarama Pillai 313. In or about May 2006, R. Pillai saw an advertisement in a local Indian paper offering job opportunities for pipefitters in the United States. He called the number in the advertisement and eventually met with Salimon. Salimon told R. Pillai that Signal would begin his green card application when he arrived in the United States, and that the process would take approximately ten months.
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3 J4. In or about June or July 2006, R. Pillai traveled to Cochin, India for an interview and skills test. Salimon and another representative of Signal reaffirmed that Signal would apply for R. PilIai' s green card.
315. R. Pillai also attended a meeting in October 2006, at which Salimon, Dewan, and at least one other Agent were present. They explained that as soon as the workers began working in the United States, Signal would begin their green card applications. The process would take approximately ten months, at the end of which the workers would be able to bring their families to the United States. At the October meeting, R. Pillai was required to sign several documents. The Agents told him that he had to sign each document to come to the United States, but they did not explain the contents of the documents, and R. Pillai did not understand what they said.
316. R. Pillai ultimately paid Pol, Burnett, and Dewan approximately 900,000 rupees (approximately $19,855) in "recruitment fees." To raise the money for these fees, R. Pillai took out three loans at 8.5 percent monthly interest, secured by his brother's house and all of his family's jewelry.
317. On or about November 17, 2006, R. Pillai met with Dewan to collect his plane ticket. At this meeting, he signed additional documents that were not explained to him.
318. In the United States, R. Pillai was appalled by the unsanitary living conditions, the unsafe work environment, Signal's discriminatory behavior, and the substantial fees Signal required him to pay for room and board. R. Pillai felt he had no choice but to endure these conditions and continue to work for Signal, however, because he was afraid that if he complained, he would be sent back to India, where he would be unable to repay the debt he had incurred to pay Dewan, Pol, and Burnett.
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319. R. Pillai relied upon Defendants' promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants' "recruitment fees," his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would take adverse immigration action against him, R. Pillai felt intimidated into acquiescence and compelled to continue working for Signal.
Aby Molathu Poulose 320. In or about March or April of2006, A. Poulose saw an advertisement in a Dubai newspaper which promised an opportunity to work in the United States and to obtain an H-2B visa and a green card. A. Poulose called Dewan Consultants and was told to attend a meeting in Dubai. 321. At that meeting, Dewan explained that workers hired by Signal would travel to the United States on H-2B visas and would receive green cards within nine to nineteen months. Dewan explained that this process would cost700,000 rupees (approximately $15,764) and that, in the United States, the workers would earn 250,000 rupees (approximately $5,630) per month after taxes. Dewan also told A. Poulose that workers from Signal would be coming to India to administer employment tests. 322. Soon after the meeting, A. Poulose called Dewan to ask ifhe could meet Signal's representatives in India for the job testing. Dewan agreed. 323. At the test, Signal personnel explained to A. Poulose that Signal was the "number one shipyard" in America and that Signal had sufficient political power that A. Poulose need not to worry about his visa. They also assured A. Poulose that Signal would apply for his green card and that it would be processed while A. Poulose was working in the United States.
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324. In or about August 2006, A. Poulose attended another meeting at which Burnett, Dewan, and Salimon were present. Burnett told A. Poulose and other workers that he was a famous immigration lawyer and that 600 H-2B visas with green cards had been approved for Signal.
325. A. Poulose ultimately paid almost 800,000 rupees (approximately $18,061) to Dewan, Pol, and Burnett. In order to raise this sum, A. Poulose borrowed 300,000 rupees (approximately $7,038) at 11 percent interest using his parents' house and land as collateral. Because he was unable to secure money elsewhere, A. Poulose and his family eventually sold this property to finance the balance of his "recruitment fees." Nonetheless, by the time he was scheduled to depart for the United States, A. Poulose still needed to raise an additional 20,000 rupees (approximately $450).
326. On the morning of A. Poulose's flight to the United States, Dewan threatened to burn A. Poulose's passport unless A. Poulose paid the missing 20,000 rupees. He stated that he would not refund any of the money that A. Poulose had paid. A. Poulose ultimately paid the full amount after his father offered Dewan the money that he intended to use to pay rent that month.
327. Before Dewan gave A. Poulose his passport, he required A. Poulose to sign paperwork. A. Poulose did not have time to read the documents because his flight would leave soon.
328. After arriving in the United States, A. Poulose felt compelled to remain at Signal. His H-2B visa prevented him from working for another employer in the United States and he could not earn enough money to repay his debts if he returned to India. Therefore, he felt that he had no choice but to continue working for Signal, despite the deplorable conditions.
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329. A. Poulose relied upon Defendants' promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants' "recruitment fees," his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would institute adverse immigration action against him, A. Poulose felt intimidated into acquiescence and compelled to continue working for Signal.
Justin Poulose
330. In or about the summer of2006, 1. Poulose was working as a welder in Kerala,
India, when he saw a newspaper advertisement offering jobs for welders and pipefitters at Signal. The advertisement mentioned green cards and said that workers could obtain visas that would allow them to travel to the United States immediately. J. Poulose called the phone number listed in the advertisement and spoke to Salimon. Salimon told 1. Poulose that he could learn more about the immigration process and j ob opportunity at a meeting.
331. 1. Poulose attended the meeting that week. He met with Pol, who was introduced an official of the American company recruiting workers. He also met with Dewan and Salimon. Pol explained that J. Poulose could work for Signal. Pol said that 1. Poulose would travel to the United States on an H-2B visa and would obtain permanent residency status within one year, at which point he would be able to bring his family. Pol also stated that J. Poulose could earn around $16 to $19 per hour at Signal.
332. At the meeting, Dewan and Salimon explained that this process would cost 800,000 rupees (approximately $18,000). J. Poulose felt that this would be a good opportunity,
but he was worried that he would not be able to afford the fees.
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333. Approximately four to six weeks later, a woman from Salimon's office called J. Poulose. She explained that the fees could be reduced to 650,000 rupees (approximately $14,163). She told 1. Poulose that he should obtain the money and take a skills test. J. Poulose was hesitant, but based on the salary he had been promised, he believed that he would be able to afford the lower price and repay his debts.
334. On or about July 5, 2006, J. Poulose took and passed a skills test administered by Signal representatives. Dewan and Salimon were also present. Dewan said that J. Poulose would be able to receive permanent residency status in the United States. At a later meeting, Salimon also gave J. Poulose a letter promising employment at Signal, an H-2B visa, and permanent residency.
335. To raise the money that he paid to Dewan, Pol, and Burnett, J. Poulose took out multiple loans, including two with monthly interest rates of approximately 10.5 percent. He used his mother's wedding jewelry as collateral for one ofthese loans, and the deeds to his family's house and land as collateral for the other. He also took out a third loan with a monthly interest rate of approximately 6 percent. J. Poulose paid all three fee installments totaling approximately 650,000 rupees by November 2006.
336. On the morning of 1. Poulose's flight to the United States, he traveled to Dewan's office in Mumbai to obtain his passport. The office was crowded, and J. Poulose was forced to wait in a long line before he could meet with anyone. Eventually, J. Poulose met with a Dewan Consultants employee who insisted that J. Poulose quickly sign paperwork written in English. The employee rushed 1. Poulose to sign and did not give him time to read the documents, emphasizing that his flight would leave soon and that there were several people in
the office. At the same time, J. Poulose saw Dewan threaten a worker who did not have enough
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money to make his final payment to Dewan. Dewan told the worker that he could not go to the United States and stapled his passport shut. This made 1. Poulose nervous, and he felt pressured to sign immediately. Only after he signed the documents did he receive his passport and plane ticket.
337. After J. Poulose arrived in the United States, he learned that Signal was deducting $35 per day from his paycheck. Signal's camp manager informed J. Poulose that the company would deduct this amount from his wages even if 1. Poulose lived outside of the man camp. Because he could not afford to repay his substantial debt and pay room and board outside the man camp with these deductions, J. Poulose felt compelled to remain and work at the man camp.
338. Months later, Signal held a camp meeting where Dewan, Burnett, Sanders, Snyder, and other officials were present. Both Dewan and Burnett assured J. Poulose and other workers that they would receive their visa extensions and that Signal would continue with their green card processing. Dewan warned, however, that the workers had to follow Signal's instructions at all times if they did not want to be deported. After this meeting, J. Poulose feared that ifhe did anything to make Signal management unhappy, he would be deported and would not be able to repay his debts.
339. On or about March 10,2007, J. Poulose attended a camp meeting led by John Sanders. Sanders assured 1. Poulose and other workers that if they followed Signal's rules, they would receive green cards. However, if they organized against Signal, then they would not be able to stay. After the meeting, 1. Poulose saw notices on the man camp's notice board instructing workers to bring documents to an office at the camp in order to obtain green cards. 1. Poulose followed these instructions, and as a result believed that his visa would be extended.
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340. In or about july of2007, J. Poulose again met with Burnett. Burnett told 1. Poulose that if he continued to work for Signal, his H-2B visa could be extended, and it would eventually be possible to file a green card application. Based on this promise, 1. Poulose continued to work at Signal.
341. J. Poulose relied upon Defendants' promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants' "recruitment fees," his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would institute adverse immigration action against him, J. Poulose felt intimidated into acquiescence and compelled to continue working for Signal.
AppunniArulPrakash
342. In or about April of2006, Prakash's wife told him about ajob advertisement offering work as a welder or fitter in the United States and the opportunity to obtain a green card within 18 to 24 months. Prakash called Dewan Consultants and spoke to a representative who said that he could work at Signal and obtain a green card. The representative said that this process would cost about 700,000 rupees (approximately $15,650), and invited Prakash to attend a general meeting in May.
343. At the May 2006 meeting, Dewan explained that Prakash and other workers would work for Signal. Pol stated that Signal would file for green cards within 18 to 24 months, and that after the workers received their green cards, they would return to India then go back to America with their families. Pol and Dewan also assured those at the meeting that the green card processing would proceed as promised. Pol stated that this process would cost workers 700,000 rupees (approximately $15,650); Salimon repeated this price as well.
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344. In or about August 2006, Prakash attended another meeting where Dewan, Salimon, and Burnett were present. Burnett explained that Prakash would receive a green card within 24 months and that he could bring his family to the United States.
345. In or about November 2006, Prakash attended another meeting with Burnett, Dewan, Salimon, and Sanders. Burnett explained that Prakash would travel to the United States on an H-2B visa, which Signal would extend twice. Prakash would then receive a green card. Sanders also assured Prakash that Signal would take care of his visa.
346. Prakash ultimately paid the 700,000 rupees demanded by the Agents. To raise this money, Prakash's family mortgaged their home and land in exchange for a loan of about 400,000 rupees (approximately $9000) at twelve percent monthly interest. Prakash obtained another loan of approximately 100,000 rupees (approximately $2250) at a monthly interest rate of approximately 23 percent. He also borrowed 150,000 to 200,000 rupees (approximately $3300 to $4500) at 9 or 10 percent interest using as collateral jewelry that his wife and sister had received for their weddings, and that had significant sentimental value.
347. On the day of Prakash's flight to the United States, he traveled to Dewan's office in Mumbai to obtain his passport and plane ticket. Dewan demanded that Prakash return to Dewan his copies of original signed agreements. When Prakash resisted, Dewan threatened that Prakash would not receive his passport or plane ticket. While Prakash was waiting at the office, he saw Dewan threaten to bum another worker's passport until that man paid Dewan the remaining money that Dewan demanded. Prakash therefore feared that he would not be able to travel to the United States unless he gave Dewan his paperwork. Prakash gave Dewan all of his original documents. Dewan then insisted that Prakash sign paperwork written in English if
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Prakash wanted to receive his passport or plane ticket. Prakash knew that his flight would soon be leaving, so he quickly signed the paperwork without understanding what it said.
348. Although Prakash knew Signal would be deducting money from his paycheck for room and board before he left India, he did not realize until he arrived at Signal that the amount to be deducted was almost $1,050 per month. Because of Prakash's heavy debt burden and because he would have to pay this amount even if he lived outside of the man camp, he felt that he had no choice but to continue living at the man camp. Prakash also felt compelled to remain at Signal because Signal assured him that he could obtain a green card ifhe stayed and performed well and he believed that he would not be able to repay his debts working in India.
349. Prakash relied upon Defendants' promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants' "recruitment fees," his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would soon adverse immigration action against him, Prakash felt intimidated into acquiescence and compelled to continue working for Signal.
Sreenivasarao Raparthy 350. On or about June 26, 2006, Raparthy learned from a friend about newspaper advertisements offering the opportunity to work as a welder or pipefitter at an American
shipyard. In response to the advertisement, Raparthy attended an interview session, where Dewan and Burnett were present. At the interview session, Dewan and Burnett told him that if he worked in the United States, he could obtain an H-2B visa and then a green card.
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351. The same day, Raparthy took a written test administered by Signal employees. Raparthy passed the test, and the employees gave him paperwork promising an H-2B visa and permanent residency.
352. Approximately three days later, Raparthy attended a meeting with Dewan. At that meeting, Dewan assured Raparthy that he could travel to the United States on an H-2B visa. Dewan also told Raparthy that an H-2B visa extension and a green card application would be filed without Raparthy needing to take additional steps. Dewan gave Raparthy a document signed by Burnett, which promised an H-2B visa and permanent residency.
353. Following Dewan's instructions, Raparthy paid approximately 600,000 rupees (approximately $12,500) to Dewan, Burnett, and Pol. To raise the money for these fees, Raparthy borrowed approximately one-third of the amount from a bank at three percent monthly interest. He borrowed another third at six percent interest using his wife's and mother's gold jewelry as collateral. He borrowed the balance from friends.
354. On the day of his flight to the United States, Dewan's agents insisted that Raparthy sign additional paperwork if he wanted to receive his passport or plane ticket. Raparthy asked ifhe could read the paperwork but was told that he would miss his flight ifhe reviewed the paperwork. Raparthy signed, and only then received his passport and ticket.
355. After Raparthy arrived in the United States, he discovered that Signal deducted approximately $245 from his paycheck each week for room and board. Raparthy asked Darrell Snyder and other Signal management if he could live outside the man camp, but Snyder told Rapartby that Signal would deduct the amount from his paycheck even if he lived elsewhere. Raparthy felt compelled to continue living at the man camp because he could not afford to repay his debt if Signal continued to deduct room and board and he paid for rent elsewhere.
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356. Raparthy relied upon Defendants' promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants' "recruitment fees," his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would institute adverse immigration action against him, Raparthy felt intimidated into acquiescence and compelled to continue working for Signal.
Mookaparambilltty Raveendranathan 357. In or about late 2005, Raveendranathan saw a newspaper advertisement in Abu Dhabi offering the opportunity to work in the United States. Raveendranathan called the phone number listed on the advertisement and spoke with Dewan. Dewan told Raveendranathan to attend an upcoming meeting at a hotel in Abu Dhabi. 358. Approximately one month later, Raveendranathan attended the meeting. Only two other potential workers were present. Dewan gave a presentation and stated that the opportunity to work in the United States would cost 500,000 rupees (approximately $10,600). Raveendranathan was hesitant to pursue the opportunity because he thought the cost was too high. 359. In or about February 2006, a friend told Raveendranathan that he had given money to Dewan Consultants. Raveendranathan called Salimon, who told Raveendranathan to attend another upcoming meeting at a hotel. Dewan and two other people led that meeting. Dewan explained to the audience that they were looking for employees to work in the United States for Signal and obtain a visa and permanent residency. Dewan explained that the workers would receive green cards after arriving in the United States and could bring their families for an additional fee. He again said that this process would cost 500,000 rupees (approximately
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$10,600), which would include payments to Dewan, Pol, and Burnet. Dewan explained that Pol and Burnett worked with Signal.
360. Shortly after the meeting, Raveendranathan took a skills test administered by Signal employees. He was then interviewed by Signal's piping superintendent. These Signal employees told Raveendranathan that he would obtain an H-2B visa within 6 months, and would receive a green card within 18 months to 2 years.
361. Raveendranathan paid all of the fees demanded by Dewan, Pol, and Burnett. He raised the money for these fees by mortgaging his home and taking out a loan at an interest rate of approximately 13.5 percent.
362. The day that Raveendranathan was scheduled to fly to the United States, he met with Dewan at his office in Mumbai. Dewan refused to give Raveendranthan his passport until Raveendranathan paid the remaining balance of his fees and gave Dewan all of the documents relating to his recruitment. Then, just before Raveendranathan left for the airport, Dewan required Raveendranthan to sign several documents. Raveendranathan did not understand the documents, but he felt that he had no choice but to sign because he had already paid so much money to the Agents and knew that they would not refund these fees.
363. After Raveendranathan arrived at Signal, Signal deducted approximately $400 to $450 each week from his paycheck for room and board. Because this cost would be deducted even if he lived elsewhere, he felt compelled to remain at the man camp. He also feared that if he complained, he might be fired or deported.
364. In or about February 2007, Dewan came to Signal and explained to Raveendranathan and the other workers that their visas would be extended, and that they would eventually receive green cards. Raveendranathan felt compelled to remain at Signal because
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Defendants had promised him a green card. He was afraid that if he were sent back to India, he would not be able to repay his debts.
365. Raveendranathan relied upon Defendants' promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants' "recruitment fees," his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would institute adverse immigration action against him, Raveendranathan felt intimidated into acquiescence and compelled to continue working for Signal.
Balwinder Singh 366. B. Singh was recruited in or about 2006. 367. During meetings with Dewan and Burnett in India in or about mid-2006, Dewan and Burnett made numerous representations that led B. Singh to believe that in exchange for paying thousands of dollars in "recruitment fees," Signal and the Agents would assist B. Singh with applying for and receiving permanent residency in the United States. 368. In reliance on these promises, B. Singh incurred substantial debt and paid thousands of dollars in "recruitment fees" to Dewan, Burnett, and Pol. 369. After arriving in the United States, B. Singh felt compelled to remain at Signal's man camp despite crowded housing because, among other reasons, Signal would deduct living expenses from his paycheck even ifhe lived elsewhere, his H-2B visa did not permit him to work for another U.S. employer, Signal constantly monitored the workers and threatened to deport them if they complained about the horrible conditions at Signal, and he believed that he would face financial ruin and bankruptcy if he returned to India.
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370. B. Singh relied upon Defendants' promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants' "recruitment fees," his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would institute adverse immigration action against him, B. Singh felt intimidated into acquiescence and compelled to continue working for Signal.
Ranjit Singh 371. In or about Mayor June of 2006, R. Singh saw an advertisement in a Dubai newspaper for a welding job at Signal. The advertisement included Dewan Consultants' name and stated that permanent residency visas would be available for workers and families. R. Singh called Dewan's office and spoke with one of his employees, who told R. Singh to travel to the New Delhi office with 40,000 rupees (approximately $873) to apply for the job. 372. At Dewan's office, Dewan's employee explained to R. Singh and approximately twelve other applicants that they would travel to the United States on a visa, the visa would be extended, and they would obtain a green card within two or three years. The employee assured them that American lawyers would handle the permanent residency visa process. The employee also explained that the process would cost between 650,000 and 700,000 rupees (approximately $14,000 and $15,000) after travel expenses. At another meeting approximately two weeks later and in subsequent conversations, the employee explained that R. Singh would pay the fees to Dewan, Burnett, and Pol. 373. R. Singh paid these "recruitment fees" in approximately three installments in or about and between May and October of 2006. To raise the money for the fees, R. Singh emptied his savings, borrowed money from friends and his wife's parents, and sold his wife'sjewe1ry. R.
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•
Singh's father also gave up title to two acres of property, which included his farm and home, in exchange for loans of totaling approximately 400,000 rupees (approximately $8,800).
374. After R. Singh had raised the money needed to pay the fees, he met with Dewan and Burnett. They both assured R. Singh that he would receive a green card.
375. In or about October 2006, R. Singh quit his job in Dubai in order to attend his
interview at the United States Consulate. 376. Just before R. Singh's flight to the United States, Dewan forced him to sign
several papers in English, which R. Singh does not speak or read. Dewan and his employee assured him that the papers were related to legal work. Dewan refused to explain to R. Singh
what he was signing. R. Singh only received his passport back after he signed this paperwork.
377. R. Singh relied upon Defendants' promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants' "recruitment fees," his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would institute adverse immigration action against him, R. Singh felt intimidated into acquiescence and compelled to continue working for Signal.
Shanmugam Subramanian 378. In or about 2006, Subramanian was working as a pipefitter in Singapore when a friend in India sent him a newspaper advertisement offering jobs in the United States. It stated that workers would travel to the United States on H-2B visas and would then receive green cards. Subramanian quit his job in Singapore and traveled to India to respond to the advertisement. He arrived in India in or about April 2006.
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379. In India, Subramanian attended a meeting where he met Salimon and filled out an application. He later met Pol, Dewan, and Salimon for an interview. After the interview, Salimon assured Subramanian that if he was selected and accepted the job, Signal would apply for his green card once he arrived in the United States. Salimon soon called Subramanian to tell him he had been selected for the job.
380. Soon thereafter, Subramanian met with Salimon, who gave him a document stating that Subramanian would need to pay Dewan, Pol, and Burnett a series of payments totaling 600,000 rupees (approximately $13,200).
381. Subramanian paid all the fees demanded by the Agents. In order to pay these fees, Subramanian used the money he had saved from his job in Singapore and pledged his mother's and sister's jewelry as collateral in exchange for a loan of350,000 rupees (approximately $7,700) at 5 percent monthly interest.
382. When he arrived at Signal, Subramanian was appalled at the squalid living conditions. He also learned that approximately $1,050 per month would be .deducted from his wages, regardless of whether he chose to live at the man camp. Subramanian felt that he had no choice but to stay with Signal because he needed to repay the substantial debts he had incurred in order to take the job. Subramanian was afraid to complain about the living and working conditions because he knew that Signal fired workers who complained.
383. Subramanian relied upon Defendants' promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants' "recruitment fees," his fear that Signal would confiscate even more of his hard-earned wages,
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and his fear that Signal or Burnett would institute adverse immigration action against him, Subramanian felt intimidated into acquiescence and compelled to continue working for Signal.
Ninan John Tharakan 384. In or about May 2006, Tharakan was working in Dubai when a friend told him about an advertisement offering pipefitting jobs in the United States. Tharakan called the number that his friend gave him and spoke with a representative of Dewan Consultants. The representative invited him to an informational meeting at a hotel in Dubai. 385. At the meeting, Dewan told Tharakan that those who were hired would work for a large U.S. company. They would receive a green card after working for eighteen months. At that point, they would be able to bring their families to the United States. 386. In or about June 2006, Dewan and a Signal employee interviewed Tharakan and administered a written test. After being notified that he had passed the test, Tharakan again met with Dewan. Dewan told him that he would travel to the United States on an H-2B visa, which would be extended until his green card had been processed. Dewan said that Signal would take care of the immigration paperwork. 387. During this meeting and later meetings in or about June and July 2006, Dewan and his employees told Tharakan that he must pay 700,000 rupees (approximately $15,344) to Dewan, Pol, and Burnett for visa and green card processing. 388. Tharakan raised the money to pay the fees by selling his and his wife's wedding nngs. He used the remainder of his wife's jewelry as collateral for a loan at 13 percent interest, and took out another loan at 21 percent interest. Tharakan also used money that he had previously borrowed to buy property in India. Tharakan paid the first three installments of his fees in or about June and July 2006.
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389. In or about September 2006, Tharakan took emergency leave from his job in Dubai to attend his H-2B visa interview at the United States Consulate in India. Because Tharakan had to wait almost two months for an interview date, his employer fired him.
390. On the day of his flight to the United States, Tharakan traveled to Dewan's office, where he paid his final installment. Dewan refused to give Tharakan his passport and ticket until he had paid his fees, given Dewan his receipts, and signed two or three blank pieces of paper.
391. Upon arrival in the United States, Tharakan was shocked by the living conditions at Signal's Mississippi facility. He was also surprised to learn that Signal would deduct $35 per day from his paycheck, even if he chose to live outside of the man camp. Nonetheless, Tharakan did not feel that he could complain or leave his job due to his debt, Signal's threats of deportation, and his fears that Dewan might hurt his family.
392. Moreover, Signal officials and Burnett had told the workers during a camp meeting that Signal would extend their visas up and file their green card applications. Tharakan believed these promises and wanted to remain in the company's good favor so he would receive his green card.
393. Tharakan relied upon Defendants' promises ofperrnanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants' "recruitment fees," his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would institute adverse immigration action against him, Tharakan felt intimidated into acquiescence and compelled to continue working for Signal.
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George Pulikkeparambil Varghese 394. In or about November and December 2003, Varghese's sister-in-Iaw's father told Varghese's son about an opportunity to work in the United States as a welder. Varghese's sisterin-law told Varghese's son that there would be a meeting to learn more about the opportunity. Varghese's son attended the meeting. 395. Soon thereafter, Varghese met with Dewan and Salimon. Dewan told Varghese that his son could work in America as a welder. He explained that this process would cost at least 500,000 rupees (approximately $10,700). 396. Varghese and his son paid these fees to Dewan, Pol, and Burnett. To make these payments, Varghese sold some gold jewelry owned by the family. He also mortgaged his home to borrow a large amount of money from a bank at an interest rate of approximately 17.9 percent. Varghese and his son made their final payments to Dewan and Salimon in or about August 2004. 397. For approximately two years after he made his final payment, Varghese's son remained in India but heard nothing from Defendants. Varghese's son repeatedly called Salimon, who assured him that he would be able to go to the United States soon. 398. In or about June 2006, Varghese and his son learned from friends that Dewan Consultants was still interviewing people. Then in or about August 2006, Varghese saw a newspaper advertisement in which Dewan Consultants offered opportunities for pipefitters and welders to work in the United States. Varghese's son called Dewan Consultants and spoke with Salimon. Salimon explained that Dewan Consultants was conducting interviews for people to work for Signal and travel to the United States on an H-2B visa. Salimon said that Varghese and his son should attend a meeting on or about September 8, 2006. 399. At this meeting, Dewan and Salimon explained that they were looking for people to travel to the United States on H-2B visas, which would be extended while their green cards
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were processed. Varghese's son decided to travel to the United States and work at Signal, but he failed his visa interview and could not go. Salimon told Varghese that Varghese could work at Signal instead.
400. Varghese completed his interview process and gave Dewan Consultants his passport for visa processing. Salimon then told Varghese that he would have to pay an additional 278,000 rupees (approximately $6,308) in cash within one day. Varghese paid this fee. In order to raise the money, he borrowed some money from his brother and sisters, and used his savings to finance the remainder.
401. On the day of his flight to the United States, Varghese traveled to Dewan's office in Mumbai. A large number of people were waiting in Dewan's office, and Varghese had to wait almost the entire day before anyone at the office met with him. When Dewan's brother finally met with Varghese, he told Varghese that he had to sign a document written in English before he could receive his plane ticket. Because Varghese needed to leave for the airport immediately, he did not have enough time to read the document. He signed quickly and left the office.
402. After he arrived at Signal, Varghese worked for approximately two weeks. Signal employees then told him that there was not enough work for him, and they would let him know when he could work again. Varghese did not work for two weeks. Then, Darryl Snyder told him that he could work, but only for $9 per hour. Snyder said that if Varghese refused, he would have to go back to India. Afraid of being sent back to India, where he would not be able to repay his debts, Varghese felt that he had no choice but to work for the lower wage.
403. Varghese relied upon Defendants' promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by
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Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants' "recruitment fees," his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would institute adverse immigration action against him, Varghese felt intimidated into acquiescence and compelled to continue working for Signal.
Benny Kattukariyil Varkey 404. In or about February 2006, Varkey's co-worker told him about an opportunity from Dewan Consultants to work as a welder in the United States and obtain a green card. Varkey called Dewan Consultants and spoke with Salimon, who told him to attend a seminar in April or May. 405. In or about March 2006, Varkey called Dewan Consultants again and spoke with Salimon, who invited him to come to his office. Salimon explained that Varkey would travel to the United States on an H-2B visa that would later become a green card. He said that the total cost would be 800,000 rupees (approximately $18,080). Salimon told Varkey to look for an advertisement giving the details about a meeting at the Hilton Hotel. That same day, Varkey saw the advertisement for the meeting. This advertisement also offered the opportunity to obtain an H-2B visa and a green card. 406. At the seminar, Salimon, Dewan, and an American whom Dewan explained was a lawyer for Signal gave a presentation about the jobs at Signal. Dewan promised the workers that they would receive green cards. Similarly, the American lawyer assured them that they would travel to the United States on H-2B visas that would become green cards after nine months. After the presentation, Dewan reiterated that the cost for the green card would be 800,000 rupees (approximately $18,080). These fees would be paid to Dewan, Pol, and Burnett.
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407. In or about June 2006, Varkey took a skills test administered by a Signal employee. Salimon and Dewan were also present. The Signal representative informed Varkey that he passed. Varkey began to raise the money to pay the Agents their "recruitment fees."
408. To raise the money to pay the fees, Varkey depleted the savings that had set aside to buy a house for his family. Varkey also borrowed money from his brother and used his wife's gold jewelry as collateral to obtain a second loan. Varkey's wife had received this jewelry as a wedding gift from her parents, who had spent their life savings to purchase it. Varkey and his brother mortgaged their properties to obtain additional loans.
409. Varkey paid his first payment at Dewan's office in or about June 2006. Salimon told Varkey to sign papers written in English, which he did not fully understand. He told Varkey that the papers were for his green card processing.
410. In or about August 2006, Varkey paid his second fees installment. Shortly after he made this payment, Salimon called to tell him that the fees had been reduced to 600,000 rupees (approximately $12,960).
411. Just before Varkey left for the United States, Varkey traveled to Dewan's office in Mumbai, where he paid his final installment. Dewan told Varkey that $3 per hour would be deducted from his paycheck for room and board. Dewan also informed Varkey that his H-2B visa would have to be extended for an additional nine months before the green card processing could begin. He said that when Varkey's green card had been processed, he would return to India, after which he could go back to the United States with his family.
412. Dewan's staff also required Varkey to sign English-language documents and return all documents relating to the green card opportunity he had been promised. They refused to explain to Varkey what he was signing. The office was crowded, Varkey felt rushed, and he
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knew that he would not receive a refund if he refused to sign. Only after Varkey had paid his final fee installment, signed the English-language documents, and given Dewan the documents relating to green cards did he receive his passport.
413. In the United States, Varkey felt that he had no choice but to live in Signal's man camp because Signal would deduct $35 per day from his paycheck even ifhe lived outside of the camp. In addition, Varkey was afraid to leave his job because of his substantial debts. He knew that if he returned to India, he would not be able to repay the loans.
414. Varkey relied upon Defendants' promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants' "recruitment fees," his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would institute adverse immigration action against him, Varkey felt intimidated into acquiescence and compelled to continue working for Signal.
Shahi Vijayan 415. In or about March or April 2006, Vijayan saw a newspaper advertisement placed by Dewan Consultants offering the opportunity to obtain permanent residency in the United States. Vijayan called Dewan Consultants, and an employee invited him to an informational meeting. 416. Dewan, Salimon, Burnett, and two Signal representatives attended the meeting. Dewan explained that if workers waited for their green cards before traveling to the United States, they would have to wait eighteen months. However, ifthey traveled to the United States on H-2B visas, they could leave in six months. Their green cards would be processed between three to six months after the workers arrived in the United States. Dewan explained that Signal
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would be responsible for this process. He said that the total cost would be 800,000 rupees (approximately $18,280).
417. Signal's representatives provided the company's website address at the meeting. Vijayan reviewed the website and felt that Signal looked reputable.
418. At this time, Vijayan also had an opportunity to work in Australia. He mentioned this to Dewan, who assured him that working for Signal would guarantee Vijayan's permanent residency and allow him to bring his family to the United States. Salimon also assured Vijayan that Signal was an excellent company. Based on Salimon's assurances, Vijayan refused the job in Australia.
419. Vijayan paid the fees demanded in approximately four installments. In order to raise the money, he mortgaged his house and land at 12.5 percent interest. He also sold his wife's gold jewelry and used her wedding necklace as collateral to obtain another loan at 12.5 percent interest. Vijayan borrowed the remainder of the money from private lenders who charged high interest rates.
420. In or about August 2006, Vijayan met with Burnett and made payments to Burnett and Pol. At that meeting, Burnett guaranteed Vijayanthat he would receive a green card if he worked for Signal.
421. Just before Vijayan's flight to America, he traveled to Dewan's office in Mumbai. Dewan's employees required him to sign some documents in English, which Vijayan did not speak well. Vijayan did not fully understand the documents. Dewan's employees nonetheless rushed Vijayan and refused to give him his passport until he paid his final installment fees and signed the documents. Vijayan felt intimidated. He saw people crying because they did not have
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enough money to make their final payment and Dewan had refused to give them their passports. Vijayan signed the paperwork.
422. When Vijayan arrived in the United States, Signal also required Vijayan to sign English-language documents that he did not understand.
423. Upon arrival in Pascagoula, Vijayan learned for the first time that the company would deduct $35 from his paycheck each day for room and board, even ifhe chose not to live at the man camp. Vijayan felt compelled to live and work at Signal because he was afraid of being sent back to India, where he would be unable to repay his debts. Vijayan also stayed because Signal personnel convinced him during conversations that he could receive a green card if he remained.
424. Vijayan relied upon Defendants' promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants' "recruitment fees," his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would institute adverse immigration action against him, Vijayan felt intimidated into acquiescence and compelled to continue working for Signal.
John Yohannan 425. In or about May 2006, Yohannan saw a newspaper advertisement that Dewan Consultants had placed, offering the opportunity to work in the United States and obtain a green card. Yohannan called Dewan Consultants' local office and scheduled a meeting. 426. At that meeting, Yohannan met with Salimon, who told Yohannan that he could work for Signal, obtain a green card after working for one year, and earn a good salary. Salimon also told Yohannan that Signal was a reputable company.
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427. Shortly after that meeting, Yohannan took and passed a welding test administered by Michael Pol and a Signal employee. Pol and the Signal employee told Yohannan to contact Salimon's office. When Yohannan contacted the office, Salimon repeated his earlier promise that Yohannan would receive a green card.
428. Yohannan later attended a larger meeting, where Pol, Salimon, and Dewan again stated that Signal was a reputable American company and that Yohannan and other workers could obtain a green card and U.S. citizenship. They told Yohannan that he would earn $18 per hour at Signal and receive food and housing. Pol, Salimon, and Dewan did not mention H-2B visas or any paycheck deductions.
429. In or about August 2006, Yohannan met with Pol, Burnett, Dewan, and Salimon before his interview with the U.S. consulate. They emphasized that if the consulate asked Yohannan anything about the fees he had paid for his recruitment, he should say that he paid nothing.
430. Yohannan ultimately paid Dewan, Pol, and Burnett approximately 11,500 rupees (approximately $25,000) for this opportunity. To pay for these fees, Yohannan used his savings and took out loans at a 12 percent interest rate. He secured some of these loans by pledging his wife's jewelry as collateral.
431. Just before Yohannan flew to the United States, he met with Dewan in his Mumbai office. Dewan refused to give Yohannan his passport and airline ticket until Yohannan paid the remaining balance of his fees. Dewan demanded that Yohannan quickly sign various documents, but he rushed Yohannan and did not give him enough time to read them. Feeling rushed and anxious to get to the airport in time for his flight, Yohannan signed the documents.
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432. In the United States, Yohannan learned that Signal would deduct approximately $260 each week from his paycheck for room and board.
433. Yohannan and other Indian workers asked Sanders and other Signal employees when they would receive their green cards. The Signal employees told them that Signal would apply for their green cards at the appropriate time.
434. Yohannan relied upon Defendants' promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants' "recruitment fees," his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would institute adverse immigration action against him, Yohannan felt intimidated into acquiescence and compelled to continue working for Signal.
FIRST CLAIM FOR RELIEF THE TRAFFICKING VICTIMS PROTECTION REAUTHORIZATION ACT ("TVPRA") OF
2003 Forced Labor (18 U.S.C. § 1589) and Trafficking with Respect to Peonage, Slavery, Involuntary
Servitude, or Forced Labor (18 U.S.c. § 1590) 435. Each Plaintiffre-alleges and incorporates by reference each and every allegation contained in the preceding paragraphs as if fully set forth herein. 436. Each Plaintiff brings this claim against all Defendants. 437. Each Plaintiff is authorized to bring these civil claims against all Defendants pursuant to the civil remedies provisions of 18 U.S.C. § 1595. 438. Defendants Signal, Dewan, Burnett, and Pol attempted to and did subject each Plaintiff to forced labor in violation of 18 U.S.c. § 1589.
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439. Defendant Signal employed Plaintiffs in dangerous conditions at a guarded and gated man camp, and all Defendants falsely assured Plaintiffs that if they continued to work, Signal would assist them in applying for and receiving green cards. Defendants controlled Plaintiffs' housing, food, access to medical care, and other basic needs, and if Plaintiffs did not continue working for Signal, they would have been cut offfrom those needs.
440. Furthermore, the substantial "recruitment fees" that Defendants coerced Plaintiffs into paying forced Plaintiffs to work at Signal to payoff their substantial debts.
441. Defendants knowingly attempted to and did physically restrain and/or threaten each Plaintiff with serious harm in order to obtain the labor and services of each Plaintiff in violation of 18 U.S.c. §1589(1).
442. Defendants knowingly attempted to and did obtain the labor and services of each Plaintiff using a scheme, plan, or pattern which, in the totality of the circumstances, was intended to coerce and did coerce each Plaintiff to believe that he would suffer serious harm if he were to leave the employ of Defendant Signal in violation of 18 U.S.C. § 1589(2).
443. Defendants' scheme to isolate Plaintiffs, coerce them to live in conditions causing psychological harm, and limit their outside contacts, which included unlawful discrimination in violation of 42 U.S.C. § 1981, was designed to convince Plaintiffs that they would suffer serious harm if they were to leave the employ of Signal.
444. Defendants threatened not to extend Plaintiffs' H-2B visas, not to sponsor Plaintiffs for green cards, to deport Plaintiffs, and to send them back to India if they complained about conditions at Signal, and also deceived Plaintiffs about the terms of their immigration status, each in a manner that constitutes an abuse of the legal process under 18 U.S.c. § 1589(3).
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Defendants retaliated against Plaintiffs when they sought legal advice regarding their rights and immigration status.
445. Defendants knowingly recruited, transported, harbored, provided, and/or obtained the Plaintiffs so as to procure their labor and services in violation of laws prohibiting peonage, involuntary servitude, and forced labor within the meaning of the provisions of 18 U.S.C. § 1590.
446. In violation of 18 U.S.C. § 1590, and in addition to the violations of 18 U.S.C. § 1589 set forth above, Defendants knowingly recruited, transported, harbored and/or obtained the Plaintiffs for labor or services in furtherance of Defendants' violations of the following provisions of Title 18, Chapter 77 of the U.S. Code:
a. enticing, persuading, or inducing the Plaintiffs to board an airliner and to travel to various locations throughout India and the United States, with the intent that they may be made or held in modern-day slavery, violating 18 U.S.c. § 1583;
b. knowingly and willfully holding Plaintiffs to involuntary servitude, as defined by the TVPRA, 22 U.S.c. §7l02(5)(a) and (b), thereby violating 18 U.S.c. § 1584;
c. removing, confiscating, or possessing Plaintiffs' and other class members' passports and other immigration documents in the course of violating, or with the intent to violate 18 U.S.C. §§ 1583, 1584, \589, and 1590, thereby violating 18 U.S.C. § 1592(a); and
d. attempting to violate 18 U.S.C. §§ \583, 1584, 1589, and \590, thereby violating 18 U.S.C. § 1594(a).
447. Defendants' actions evince malice and/or reckless indifference towards Plaintiffs. 448. As a proximate result ofthe conduct of Defendants, Plaintiffs have suffered injuries to their persons, businesses, and property, as well as other damages. Plaintiffs are
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entitled to recover compensatory and punitive damages in an amount to be proven at trial, including recruitment fees, other payments made to Signal agents, and attorneys' fees.
SECOND CLAIM FOR RELIEF VIOLATIONS OF THE CIVIL RIGHTS ACT OF 1866
42 U.S.C. § 1981 449. Each Plaintiffre-alleges and incorporates by reference each and every allegation contained in the preceding paragraphs as if fully set forth herein. 450. Each Plaintiff asserts this claim pursuant to 42 U.S.C. § 1981 for declaratory relief and damages against Defendant Signal. 451. The actions of Defendant Signal, as set forth herein, violated Plaintiffs' rights to receive full and equal benefit of all laws as guaranteed by 42 U.S.C. § 1981, including Plaintiffs' rights to enjoy and benefit from non-discriminatory employment relationships with Defendant Signal. 452. Specifically, Defendant Signal subjected Plaintiffs to discriminatory and offensive mandatory room and board arrangements at Signal man camps in Pascagoula. Defendant Signal did not subject its employees of non-Indian race, ethnicity, or alienage to the same or similar room and board arrangements. 453. As set forth in the preceding paragraphs, Defendant Signal also imposed discriminatory job-related requirements and adverse terms and conditions of employment to which its employees of non-Indian race, ethnicity, or alienage were not similarly subject. 454. As set forth in the preceding paragraphs, Defendant Signal also created and fostered a discriminatory work environment in which Indian workers were subjected to antiIndian invectives throughout the time Plaintiffs were employed, and in which Signal forced Sikh
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workers to shave religiously mandated beards. Signal employees of non-Indian race, ethnicity, or alienage or not ofthe Sikh religion were not subjected to a similar work environment.
455. As set forth in the preceding paragraphs, through the actions and statements of its personnel referring to and/or directed at Plaintiffs and other Indian H-2B workers, Defendant Signal maintained an objectively hostile and abusive work environment on account of Plaintiffs' race, ethnicity, religion, and alienage throughout the time Plaintiffs were employed.
456. As set forth in the preceding paragraphs, Defendant Signal's discriminatory and offensive treatment of Plaintiffs was sufficiently severe that it created a hostile work environment in violation of 42 U.S.C. § 1981 throughout the time Plaintiffs were employed.
457. Plaintiffs reasonably perceived their work environment to be hostile, abusive, and discriminatory on the basis of their race, ethnicity, religion, and alienage.
458. Defendant Signal's hostile, abusive, and discriminatory treatment of Plaintiffs and other class members was unwelcome.
459. Defendant Signal knowingly, willfully, maliciously, intentionally, and without justification acted to deprive Plaintiffs of their rights.
460. Defendants' actions evince malice and/or reckless indifference towards Plaintiffs. 461. As a direct and proximate result of Defendants' knowing, willing, and intentional actions, each Plaintiffs has been injured, and is entitled to recover compensatory and punitive damages in an amount to be proven at trial, including attorneys' fees.
THIRD CLAIM FOR RELIEF FRAUDULENT MISREPRESENTATION 462. Each Plaintiff re-alleges and incorporates by reference each and every allegation contained in the preceding paragraphs as iffully set forth herein. 463. Each Plaintiff brings this claim against all Defendants.
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464. The actions of Defendants. as set forth herein, constitute fraudulent misrepresentation under Mississippi law.
465. Specifically, Defendants, individually and through their agents, employees, and/or representatives, knowingly made materially false and untrue statements and representations to Plaintiffs regarding the nature, terms, and conditions of applications and opportunities for immigration status and employment in the United States.
466. Defendants and/or their respective agents represented to each Plaintiff that (l) Plaintiffs would be eligible for permanent residency given their employment with Signal; (2) Defendants would apply 'for permanent residency in the United States on behalf of Plaintiffs no later than 24 months after the commencement of work; and (3) Plaintiffs would have steady and ongoing work opportunities in the United States with Defendant Signal.
467. At the time each of these representations were made, Defendants knew they were false or misleading.
468. Defendants intended that the false statements made by each Defendant and/or the Defendants' respective agents, employees, and/or representatives would induce Plaintiffs to pay the exorbitant "recruitment fees," would induce Plaintiffs to leave their homes and jobs abroad, travel to the United States, and work for Signal, and would induce Plaintiffs to pay the room and board fee and other fees extracted by Signal upon the workers' arrival in the United States.
469. Each Plaintiff was entitled to, and did, rely on Defendants' representations. 470. In reasonable reliance on the false representations of Defendants and their respective agents, employees, and/or representatives regarding green cards, employment opportunities, and employment conditions, Plaintiffs paid large snms of money and incurred
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substantial debt in the guise of "recruitment fees" and other travel and immigration-related fees. Signal knew of these payments, and permitted them to be made to the Agents.
471. In reasonable reliance on the false representations of Defendants and their respective agents, employees, and/or representatives regarding green cards, employment opportunities, and employment conditions, Plaintiffs surrendered employment opportunities in India and abroad, left their homes and families behind, sold personal and real property, secured loans at usurious interest rates, traveled to the United States, and worked for Signal. Further, once in the United States, Plaintiffs continued to work for Signal after receiving repeated assurances that Defendants' prior representations were in fact true.
472. No later than the first day that Indian workers arrived at Signal, Defendants knew that Plaintiffs and their coworkers believed that Defendants had applied, or were intending to apply, for permanent residency on behalf of Plaintiffs. Defendants therefore had an obligation to tell Plaintiffs that this was not true. Defendants failed to do so.
473. Defendants' actions evince malice and/or reckless indifference towards Plaintiffs. 474. As a direct and proximate result of Defendants' knowing, willing, and intentional actions, each Plaintiff has been injured, and is entitled to recover compensatory damages, including opportunity costs, and punitive damages in an amount to be proven at trial.
FOURTH CLAIM FOR RELIEF NEGLIGENT MISREPRESENTATION 475. Each Plaintiffre-alleges and incorporates by reference each and every allegation contained in the preceding paragraphs as if fully set forth herein. 476. Each Plaintiff brings this claim against all Defendants. 477. The actions of Defendants, as set forth herein, constitute negligent misrepresentation under Mississippi law.
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478. Specifically, Defendants, individually and through their agents, employees, and/or

•

representatives, negligently made materially false and untrue statements and representations to

Plaintiffs regarding the nature, terms, and conditions of applications and opportunities for

immigration status and employment in the United States.

479. Defendants represented to each Plaintiff that (1) Plaintiffs would be eligible for

permanent residency upon the conclusion of their employment with Signal; (2) Defendants

would apply for permanent residency in the United States on behalf of Plaintiffs no later than 24

months after the commencement of work, (3) Plaintiffs would have steady and ongoing work

opportunities in the United States with Defendant Signal.

480. At the time each of these representations were made, Defendants should have

known that they were false or misleading.

481. Defendants should have known that the false statements made by each Defendant

and/or the Defendants' respective agents, employees, and/or representatives would induce

Plaintiffs to pay the exorbitant "recruitment fees"; would induce Plaintiffs to leave their homes

and jobs abroad, travel to the United States, and work for Signal; and would induce Plaintiffs to

pay the room and board fee and other fees extracted by Signal upon the workers' arrival in the

United States.

482. Each Plaintiff was entitled to, and did, rely on Defendants' representations.

483. In reasonable reliance on the negligent representations of the Defendants and their

respective agents, employees, and/or representatives regarding green cards, employment

opportunities, and employment conditions, Plaintiffs paid large sums of money and incurred

substantial debt in the guise of "recruitment fees" and other travel and immigration-related fees.

Signal knew of these payments, and permitted them to be made to the Agents.

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484. In reasonable reliance on the negligent representations of the Defendants and their respective agents, employees, andlor representatives regarding green cards, employment opportunities, and employment conditions, Plaintiffs surrendered employment opportunities in India and abroad, left their homes and families behind, sold personal and real property, secured loans at usurious interest rates, traveled to the United States, and worked for Signal. Further, once in the United States, Plaintiffs continued to work for Signal after receiving repeated assurances that Defendants' prior representations were in fact true.
485. No later than the first day that Indian workers arrived at Signal, Defendants knew that Plaintiffs and their coworkers believed that Defendants had, or were intending to, apply for permanent residency on behalf of Plaintiffs. Defendants therefore had an obligation to tell Plaintiffs that this was not true. Defendants failed to do so.
486. Defendants' actions evince malice andlor reckless indifference towards Plaintiffs. 487. As a direct and proximate result of Defendants' negligent actions, Plaintiffs have been injured, and are entitled to recover compensatory damages, including opportunity costs, and punitive damages in an amount to be proven at trial.
FIFTH CLAIM FOR RELIEF BREACH OF CONTRACT
488. Each Plaintiff re-alleges and incorporates by reference each and every allegation contained in the preceding paragraphs as if fully set forth herein.
489. Each Plaintiff brings this claim against all Defendants. 490. The actions of Defendants, as set forth herein, constitute breach of contract under Mississippi law. 491. Specifically, Defendants, individually and through their agents, employees and/or representatives, promised to assist Plaintiffs in applying for and obtaining permanent residency
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and immigration status for Plaintiffs in the United States no later than 24 months after the commencement of work, and promised Plaintiffs steady and ongoing work opportunities in the United States with Defendant Signal.
492. These promises were made in exchange for each Plaintiff's payment of fees (including recruitment, immigration application, and travel fees) to Defendants and their employees, agents, and/or representatives, and in exchange for each Plaintiff's agreement to work for Signal.
493. Each Plaintiff accepted Defendants' offers and promises; each Plaintiff paid the agreed upon fees, and performed the agreed-upon work.
494. Defendants hreached their respective contracts with each Plaintiffhy failing to comply with their binding promises regarding assistance in applying for and obtaining permanent residency and immigration status for Plaintiffs in the United States no later than 24 months after the commencement of work, and steady and ongoing work opportunities in the United States with Defendant Signal.
495. In reliance on these promises, each Plaintiff paid large sums of money and entered into substantial debts, surrendered other employment opportunities, and incurred other financial losses.
496. Defendants' actions evince malice and/or reckless indifference towards Plaintiffs. 497. As a direct result of Defendants' breach, Plaintiffs have suffered direct and consequential damages, and are entitled to recover compensatory damages, including opportunity costs, and punitive damages in an amount to be proven at trial.
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Case 2:13-cv-06218-SM-DEK Document 1 Filed 05/21/13 Page 105 of 106 PRAYER FOR RELIEF
WHEREFORE, Plaintiffs request the following relief: I. Compensatory relief, including prejudgment interest; 2. Punitive damages; 3. An award of reasonable Plaintiffs' costs, including attorneys' fees and costs; 4. Such additional and further relief as the Court may deem proper and just.
DEMAND FOR JURY TRIAL Pursuant to Rule 38 ofthe Federal Rules of Civil Procedure, Plaintiffs demand trial by jury in this action of all issues so triable.
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Dated: May 20, 2013
Robert B. McDuff, MS Bar #2532 Sibyl C. Byrd, MS Bar No. 100601 Jacob W. Howard, MS Bar No. 103256 MCDUFF & BYRD 767 North Congress Street Jackson, MS 39202 Tel: (601) 969-0802 Fax: (601) 969-0804 Fax Email: rbm@mcdufflaw.com Email: scb@mcdufflaw.com Email: jake@mcdufflaw.com
Miles N. Ruthberg, pro hac vice to be filed Benton J. Campbell,pro hac vice to be filed Christopher Harris, pro hac vice to be filed Jennifer Greenberg, pro hac vice to be filed Daniel D. Adams, pro hac vice to be filed Elizabeth C. Rowland, pro hac vice to be filed Aaron M. Safane, pro hac vice to be filed LATHAM & WATKINS LLP 885 Third Avenue New York, New York 10022 Tel: (212) 906-1200 Fax: (212) 751-4864 E-mail: miles.ruthberg@lw.com E-mail: benton.campbell@lw.com E-mail: christopher.harris@lw.com E-mail: jennifer.greenberg@lw.com E-mail: daniel.adams@lw.com E-mail: elizabeth.rowland@lw.com E-mail: aaron.safane@lw.com
Attorneys/or Plaintiffs
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 Case 2:13-cv-06218-SM-DEK Document 44 Filed 10/18/13 Page 1 of 10

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF MISSISSIPPI
SOUTHERN DIVISION

ACHARI, ET AL.

PLAINTIFFS

v.

CAUSE NO. 1:13CV222-LG-JMR

Consolidated with: CAUSE NO. 1:13CV327-HSO-RHW

SIGNAL INT’L, LLC, ET AL.

DEFENDANTS

CHAKKIYATTIL, ET AL. v. SIGNAL INT’L, LLC, ET AL.

PLAINTIFFS CAUSE NO. 1:13CV318-LG-JMR
DEFENDANTS

KRISHNAKUTTY, ET AL v. SIGNAL INT’L, LLC, ET AL.

PLAINTIFFS CAUSE NO. 1:13CV319-LG-JMR
DEFENDANTS

ORDER CONSOLIDATING CASES AND TRANSFERRING TO THE UNITED STATES DISTRICT
COURT FOR THE EASTERN DISTRICT OF LOUISIANA
BEFORE THE COURT are the Motion [33] to Consolidate filed by Signal
International, Inc. and Signal International, LLC (“Signal”) in cause no. 1:13cv222-
LG-JMR, and the Motions to Transfer filed by Signal in each of the above-captioned
cases (the “Mississippi cases”). The motions are opposed by the plaintiffs. After due

Case 2:13-cv-06218-SM-DEK Document 44 Filed 10/18/13 Page 2 of 10
consideration, the Court concludes that consolidation for the purpose of considering transfer is appropriate, and that the Mississippi cases should be transferred to the United States District Court for the Eastern District of Louisiana, where a substantially similar case was first filed and is pending. Accordingly, the motions to consolidate and transfer will be granted. The Court declines to rule on any remaining motions, leaving them for determination by the transferee court.
PROCEDURAL HISTORY Signal seeks consolidation, stay and transfer of four cases to the Eastern District of Louisiana. The four are this case (“Achari”), Chakkiyattl v. Signal, No. 13cv318-LG-JMR (“Chakkiyattl”), Krishnakutty v. Signal, No. 13cv319-LG-JMR (“Krishnakutty”), and Devassy v. Signal, 1:13cv327-HSO-RHW (“Devassy”).1 Signal argues that these cases are closely related to a similar lawsuit filed in the Eastern District of Louisiana in March 2008, David, et al. v. Signal, et al., No. 2:08-CV1220-JCZ-DEK ("David"). Signal submits that under the "first filed" rule, the four cases should be transferred so that their issues can be resolved with David. The Eastern District of Louisiana district judge summarized the David plaintiffs’ claims as alleging a scheme to lure foreign workers to work for Signal in Mississippi and Texas with the promise of permanent residence in the United States. Once in the United States, the David plaintiffs alleged they were subjected to discrimination and adverse working and living conditions. The plaintiffs allege
1 Devassy was recently consolidated with Achari. -2-

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that the recruitment defendants obtained millions of dollars in fees and Signal obtained workers for a lesser cost than if it hired American workers. David, Order & Reasons at 4, Jan. 4, 2012 (denying motion to certify class).
Signal is one of twelve defendants in David.2 The plaintiffs in David are a number of Indian nationals who were Signal employees. Their Third Amended Complaint asserts violations of the Racketeer Influenced and Corrupt Organizations Act (RICO), the Victims of Trafficking and Violence Protection Act (TVPA), 42 U.S.C. § 1981, 42 U.S.C. § 1985, the Fair Labor Standards Act (FLSA), and claims of fraud/negligent misrepresentation, and breach of contract. Several plaintiffs also bring individual claims of retaliation under § 1981 and § 1985, and claims of false imprisonment, assault, battery, and infliction of emotional distress.
The plaintiffs in these Mississippi cases were previously among the plaintiffs in the David case who sought to be certified as a class. After class certification was denied by the Louisiana district court judge, they filed complaints in this Court.
2 The David Defendants are: Signal International L.L.C; Malvern C. Burnett; Gulf Coast Immigration Law Center, L.L.C.; Law Offices of Malvern C. Burnett, A.P.C.; Indo-Ameri Soft L.L.C.; Kurella Rao; J & M Associates, Inc. of Mississippi; Billy R. Wilks; J & M Marine & Industrial, L.L.C.; Global Resources, Inc.; Michael Pol; Sachin Dewan; and Dewan Consultants Pvt. Ltd. (a/k/a MedTech Consultants). Signal has also filed claims against a third-party defendant, Zito Companies, LLC.
-3-

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The plaintiffs in Achari are a number of Indian nationals who allege that Signal, through recruiters, lured them to the United States to work in deplorable, discriminatory conditions with the promise of permanent U.S. residency. (Am. Compl. 3-7, ECF No. 26). They assert claims of violation of the TVPA, 42 U.S.C. § 1981, fraudulent misrepresentation, negligent misrepresentation, and breach of contract.
The plaintiffs in Chakkiyattil are a number of Indian nationals who allege that Signal, through recruiters, lured them to the United States to work in deplorable, discriminatory conditions with the promise of permanent U.S. residency. Chakkiyattil, No. 1:13cv318-LG-JMR, Compl. passim, ECF No. 1. They assert claims of violation of the TVPA, 42 U.S.C. § 1981, fraudulent misrepresentation, negligent misrepresentation, and breach of contract. Id. 111121.
The plaintiffs in Krishnakutty are a number of Indian nationals who allege that Signal, through recruiters, lured them to the United States to work in deplorable, discriminatory conditions with the promise of permanent U.S. residency. Krishnakutty, No. 1:13cv319-LG-JMR, Compl. 2, ECF No. 1. They bring claims against all defendants for violation of the TVPA, RICO, 42 U.S.C. § 1981 & 1985, fraud, negligent misrepresentation, breach of contract, “money had and received,” breach of special/confidential relationship, and against certain defendants, breach of fiduciary duty.
-4-

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The plaintiffs in Devassy are a number of Indian nationals who allege that Signal, through recruiters, lured them to the United States to work in deplorable, discriminatory conditions with the promise of permanent U.S. residency. Devassy, No. 1:13cv327-HSO-RHW, Compl. 1-2, ECF No. 1. They assert claims of violation of the TVPA, 42 U.S.C. § 1981, fraudulent misrepresentation, negligent misrepresentation, and breach of contract.
DISCUSSION I. Motion to Consolidate
Signal contends that the above cases should be consolidated only for the purpose of deciding whether the first-filed rule requires the Court to transfer the cases to the United States District Court for the Eastern District of Louisiana. Signal argues that the first-filed rule applies equally to all the cases it wishes to consolidate for the purpose of transfer.
The plaintiffs argue that consolidation will not aid the Court as a matter of convenience and judicial economy. Plaintiffs contend that even though all four cases stem from David, they bring different claims against different defendants, and so individual attention must be given to each case in making the transfer decision.
The Court has broad discretion in determining whether and to what extent to consolidate cases. Ctr. for Biological Diversity, Inc. v. BP Am. Prod. Co., 704 F.3d 413, 432 (5th Cir. 2013) (“The trial court’s managerial power is especially strong and flexible in matters of consolidation.”); Mills v. Beech Aircraft Corp., Inc., 886
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F.2d 758, 762 (5th Cir. 1989). The question of whether these cases should be transferred to the Eastern District of Louisiana pursuant to the first-filed rule will require analysis of a single body of law in relation to each case. The summary above of each case shows that there is substantial similarity in the underlying facts and theories of recovery. The Court finds that considering the cases together will result in judicial economy. Accordingly, the Motion to Consolidate will be granted. II. Motion to Stay and Transfer Pursuant to the First-to-File Rule
The "first to file" rule permits a district court to decline jurisdiction over an action when it involves the same parties and issues as a previously-filed action in another court. When related cases are pending before two federal courts, the court in which the case was last filed may dismiss or transfer the case if it involves substantially similar issues which can be resolved in the earlier-filed action. See W. Gulf Mar. Ass'n v. ILA Deep Sea Local 24, 751 F.2d 721, 728-29 (5th Cir. 1985) and Save Power Ltd. v. Syntek Fin. Corp., 121 F.3d 947, 950 (5th Cir. 1997). “The concern manifestly is to avoid the waste of duplication, to avoid rulings which may trench upon the authority of sister courts, and to avoid piecemeal resolution of issues that call for a uniform result.” W. Gulf Mar. Ass'n, 751 F.2d at 728.
The Court's inquiry is focused on whether the cases "substantially overlap," but where the overlap is "less than complete, the judgment is made case by case, based on such factors as the extent of overlap, the likelihood of conflict, the comparative advantage and the interest of each forum in resolving the dispute.” Save Power Ltd., 121 F.3d at 951. The first-to-file rule is a discretionary doctrine.
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Cadle Co. v. Whataburger of Alice, Inc., 174 F.3d 599, 603 (5th Cir. 1999) (citing Kerotest Mfg. Co. v. C-O-Two Fire Equip. Co., 342 U.S. 180, 183-84 (1952)). It is not a rigid or inflexible rule to be mechanically applied. Mann Mfg., Inc. v. Hortex, Inc., 439 F.2d 403, 407 (5th Cir. 1971). The decision of whether to apply the first-to-file rule involves determinations concerning "[w]ise judicial administration, giving regard to conservation of judicial resources and comprehensive disposition of litigation." Kerotest, 342 U.S. at 183.
In support of its motion, Signal argues that the first to file rule applies because the issues and parties in the David case completely encompass the issues and parties in the Mississippi cases. Signal provides a press release by the Southern Poverty Law Center as evidence that the lawyers for the plaintiffs acknowledged the substantial overlap of David and the Mississippi cases. (Def. Memo. Ex. 1, ECF No. 12-1). In response, the plaintiffs argue that 1) there is a serious question of whether the Louisiana court can exercise personal jurisdiction over all of the named defendants; 2) there is no overlap of parties because the plaintiffs in the Mississippi cases are not parties to the David case; and 3) denial of class certification in David shows that there is no substantial overlap of issues.
In regard to the question of substantial overlap of parties and issues, the Court finds that both exist here. The fact that the plaintiffs are no longer parties to the David case does not negate the presence of many defendants in common.3 The
3 Defendants common to David and Achari are Signal International L.L.C; -7-

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Mississippi defendants are merely subsets of the David defendants.
Malvern C. Burnett; Gulf Coast Immigration Law Center, L.L.C.; Law Offices of Malvern C. Burnett, A.P.C..; Global Resources, Inc.; Michael Pol; Sachin Dewan; and Dewan Consultants Pvt. Ltd. (a/k/a MedTech Consultants). All of the Achari defendants are named in David.
Defendants common to David and Chakkiyattil are Signal International L.L.C; Malvern C. Burnett; Gulf Coast Immigration Law Center, L.L.C.; Law Offices of Malvern C. Burnett, A.P.C.; J & M Associates, Inc. of Mississippi; Billy R. Wilks; J & M Marine & Industrial, L.L.C.; Global Resources, Inc.; Sachin Dewan; and Dewan Consultants Pvt. Ltd. (a/k/a MedTech Consultants). All of the Chakkiyattil defendants are named in David.
Defendants common to David and Krishnakutty are Signal International L.L.C; Malvern C. Burnett; Gulf Coast Immigration Law Center, L.L.C.; Law Offices of Malvern C. Burnett, A.P.C.; Indo-Ameri Soft L.L.C.; Kurella Rao; Global Resources, Inc.; Sachin Dewan; and Dewan Consultants Pvt. Ltd. (a/k/a MedTech Consultants). All of the Krishnakutty defendants are named in David.
Defendants common to David and Devassy are Signal International L.L.C; Malvern C. Burnett; Gulf Coast Immigration Law Center, L.L.C.; Law Offices of Malvern C. Burnett, A.P.C.; Indo-Ameri Soft L.L.C.; Kurella Rao; Global Resources, Inc.; Michael Pol; Sachin Dewan; and Dewan Consultants Pvt. Ltd. (a/k/a MedTech Consultants). All of the Devassy defendants are named in David.
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Further, the issues are almost identical. In all cases, the plaintiffs allege a human trafficking scheme that induced them to emigrate from India with the unfulfilled promise of permanent United States residency, and the imposition of adverse working and living conditions. The theories of recovery in all of the Mississippi cases are also presented in the David case. Finally, it should be noted that failing to meet the commonality requirements for class certification is not equivalent to a lack of substantial overlap of issues. There is such substantial overlap that the Mississippi cases should be transferred to the Eastern District of Louisiana for consideration of the issues.
The plaintiffs question the ability of the Louisiana court to assert personal jurisdiction over all of the defendants. If there is such a question in these cases, it must also be addressed in David, as all of the defendants named in the Mississippi cases are also named in David. It would be improper for this Court to analyze the Louisiana court’s jurisdiction in any event. The Fifth Circuit has rejected the proposition that the first-to-file rule requires the second-filed court to consider the jurisdiction of the first. Cadle Co. v. Whataburger of Alice, Inc., 174 F.3d 599, 60405 (5th Cir. 1999). “Once the likelihood of a substantial overlap between the two suits has been demonstrated, it is no longer up to the second filed court to resolve the question of whether both should be allowed to proceed.” Id. at 606 (citation and internal quotation marks omitted). “[T]he first-to-file rule ‘not only determines which court may decide the merits of substantially similar issues, but also establishes which court may decide whether the second suit filed must be dismissed,
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stayed or transferred and consolidated.’” Street v. Smith, 456 F. Supp. 2d 761, 768 (S.D. Miss. 2006) (citation and marks omitted).
For these reasons, the Court finds that transfer to the United States District Court for the Eastern District of Louisiana is appropriate.
IT IS THEREFORE ORDERED AND ADJUDGED that the Motion [33] to Consolidate filed by Signal International, Inc. and Signal International, LLC (“Signal”) in cause no. 1:13cv222-LG-JMR, is GRANTED. Civil Action Nos. 1:13cv318 and 1:13cv319 shall be consolidated with Civil Action No. 1:13cv222, and that Achari v. Signal International, LLC, Civil Action No. 1:13cv222-LG-JMR shall serve as the lead case with Chakkiyattl v. Signal International, LLC, No. 13cv318LG-JMR and Krishnakutty v. Signal International, LLC, No. 13cv319-LG-JMR designated as member cases. All subsequent pleadings relating to these causes of action should be filed in the lead case only.
IT IS FURTHER ORDERED AND ADJUDGED that the Motion [11] to Transfer Pursuant to First-Filed Rule filed by Signal International, LLC, is GRANTED. The above-captioned consolidated cases are TRANSFERRED to the United States District Court for the Eastern District of Louisiana.
SO ORDERED AND ADJUDGED this the 18th day of October, 2013.
s/ Louis Guirola, Jr.
LOUIS GUIROLA, JR. CHIEF U.S. DISTRICT JUDGE
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 Case 2:13-cv-06218-SM-DEK Document 200 Filed 03/03/14 Page 1 of 158

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA

LAKSHMANAN PONNAYAN ACHARI, et al., Plaintiffs,
v. SIGNAL INTERNATIONAL, LLC, et al., Defendants.

CIVIL ACTION
No. 13-6218 (c/w 13-6219, 13-6220, 13-6221)
Section “E”

Related Cases:
KURIAN DAVID, et al., Plaintiffs,
v. SIGNAL INTERNATIONAL, LLC, et al., Defendants.

CIVIL ACTION No. 08-1220 Section “E”

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION, et al.,
Plaintiffs, v. SIGNAL INTERNATIONAL, LLC, et al., Defendants.

CIVIL ACTION No. 12-557 Section “E”

Applies To: Achari v. Signal, No. 13-6218

SECOND AMENDED COMPLAINT AND JURY DEMAND

Case 2:13-cv-06218-SM-DEK Document 200 Filed 03/03/14 Page 2 of 158
TABLE OF CONTENTS Page
INTRODUCTION ...........................................................................................................................1 Defendants’ Conduct Violated Congress’s Clear Prohibition Against Human Trafficking .....................................................................................................................7
JURISDICTION AND VENUE ......................................................................................................9 PARTIES .........................................................................................................................................9 SUBSTANTIVE ALLEGATIONS ...............................................................................................16
In the Aftermath of Hurricane Katrina, Signal Contracts with Dewan, Burnett, and Pol to Bring Temporary Workers to the United States at No Cost to Signal...............16
Defendants File Petitions for Temporary H-2B Visas, Not Green Cards..........................18 Plaintiffs Incur Substantial Debt to Afford High “Recruitment Fees” ..............................20 Plaintiffs Arrive in Signal’s Pascagoula, Mississippi Man Camp and are Subjected
to Degrading and Discriminatory Conditions ..............................................................22 Plaintiffs Experienced Other Discrimination by Signal and its Employees Due to
their Race, Ethnicity, Religion, and Alienage..............................................................27 Signal and the Agents Continued to Mislead the Plaintiffs About the Terms of
their Employment.........................................................................................................30 In an Attempt to Quell Rising Worker Dissatisfaction, Signal Sends Three
Workers Back to India, One of Whom Attempts Suicide............................................32 Signal, Assisted by Burnett and Dewan, Used Fraudulent and Coercive Tactics to
Keep Plaintiffs in the Pascagoula Camp ......................................................................34 Malvern Burnett Purported to Act as Attorney to Plaintiffs, but In Reality Was
Working Solely on Behalf of Defendants ....................................................................36 Plaintiffs Each Relied on the Defendants’ Representations ..............................................38 FIRST CLAIM FOR RELIEF .....................................................................................................141 THE TRAFFICKING VICTIMS PROTECTION REAUTHORIZATION ACT
(“TVPRA”) OF 2003 AGAINST ALL DEFENDANTS...........................................141 SECOND CLAIM FOR RELIEF ................................................................................................144
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Case 2:13-cv-06218-SM-DEK Document 200 Filed 03/03/14 Page 3 of 158 VIOLATIONS OF THE CIVIL RIGHTS ACT OF 1866 42 U.S.C. § 1981 BROUGHT AGAINST SIGNAL ..............................................................................144
THIRD CLAIM FOR RELIEF ....................................................................................................146 FRAUDULENT MISREPRESENTATION UNDER MISSISSIPPI LAW AGAINST ALL DEFENDANTS ..............................................................................146
FOURTH CLAIM FOR RELIEF ................................................................................................148 NEGLIGENT MISREPRESENTATION UNDER MISSISSIPPI LAW AGAINST ALL DEFENDANTS ..............................................................................148
FIFTH CLAIM FOR RELIEF .....................................................................................................150 BREACH OF CONTRACT UNDER MISSISSIPPI LAW AGAINST ALL DEFENDANTS .........................................................................................................150
PRAYER FOR RELIEF ..............................................................................................................153 DEMAND FOR JURY TRIAL ...................................................................................................153
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INTRODUCTION 1. This is a human trafficking case brought by foreign workers trafficked into the State of Mississippi. It is grounded in laws passed by the United States Congress to combat this very problem. Rather than hiring new workers from the Gulf Coast in the wake of a devastating hurricane, the Defendants instead turned the Plaintiffs into an exploitable source of cheap labor. The Defendants then worked together to defraud each of the Plaintiffs out of tens of thousands of dollars, falsely promised them assistance in applying for and obtaining permanent residence in the United States, trafficked them into the United States, forced them to live in squalid and unsanitary conditions that damaged Plaintiffs’ health and psychological well-being, discriminated against them on the basis of their race, ethnicity, religion, and alienage, and threatened them with financial ruin and adverse immigration action if they balked. 2. Plaintiffs Lakshmanan Ponnayan Achari, Varghese Varkey Abraham, Kodakeril Baby Biji, Subhashithan Bahuleyan, Xavier Disoliyan, Rajankunju Geevarghese, Jomon George, Shaiju Vadakkal George, Praveen Kulathum Muriyil Gopalakrishnan, Mouleswararao Guntamukkala, Eldose Isac, Raveendranathan Mookaparambil Itty, Joy Jacob, Biju John, Shibu Joseph, Thansilas Joseph, Kulath Somanathan Kalayam, Sunilkumar Marottikkal Kuttan, Bhaskaran Sreedharan Kutty, Parshottam Ramchandra Mangani, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Jacob Mazhukkattu Mathew, Johny Mathew, Nandhakumar Nagaraj, Shaji Veluthalakuzhiyil Nanoo, Mangalan Chandrasekharan Pillai, Radhakrishna Pillai Sivarama Pillai, Aby Molathu Poulose, Justin Poulose, Appunni Arul Prakash, Sreenivasarao Raparthy, Nibu Raju, Balwinder Singh, Ranjit Singh, Savinder Singh, Shanmugam Subramanian, Ninan John Tharakan, Kittayi Sunil Kumar Therattil, Moni Panikulangara Thomas, Thenooran Kumaran Unnikrishnan, Benny Chittilappilly Vareed, George Pulikkeparambil Varghese, Kuliyanickal Paily Varghese (represented by his estate), Benny Kattukariyil Varkey, Shahi 1

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Vijayan, and John Yohannan, each a former employee at Signal International, LLC and Signal International, Inc.’s (collectively “Signal”) Pascagoula, Mississippi facility, bring this action to recover for the unlawful and fraudulent behavior by Defendant Signal and Signal’s agents Malvern C. Burnett, the Law Offices of Malvern C. Burnett, Gulf Coast Immigration Law Center, LLC, Sachin Dewan, Dewan Consultants Pvt. Ltd., Michael Pol, and Global Resources Inc. (referred to hereafter as the “Agents”).
3. Signal is a Gulf Coast-based marine and fabrication company. In the aftermath of Hurricane Katrina, Signal set out to recruit several hundred foreign workers to work as temporary welders and pipefitters in Signal’s Pascagoula, Mississippi facility. Signal also recruited workers to work at a Signal facility in Orange, Texas.
4. To assist in that process, Signal retained Michael Pol and his company Global Resources, Inc. (“Global”), a labor recruitment firm with operations in Mississippi; Malvern C. Burnett, an attorney based in Mississippi and Louisiana; and Sachin Dewan, a labor recruiter in India, to recruit workers on Signal’s behalf. Signal also executed a power of attorney authorizing Dewan’s company, Dewan Consultants Pvt. Ltd., to recruit for Signal abroad.
5. The cornerstone of the Defendants’ scheme was the tantalizing prospect that Signal would be able to hire a skilled workforce at effectively no cost by forcing the Plaintiffs and their coworkers to foot the bill for their own recruitment, immigration processing, and travel. Indeed, an April 18, 2006 “Skilled Worker Recruitment Agreement” between Signal and Global that set this scheme in motion expressly stated that the workers would be delivered at no cost to Signal and that all other charges, expenses and fees would be paid by the workers themselves or by Global, who in turn would be reimbursed through deductions from the Plaintiffs’ wages. In short, Defendants paid nothing; the future employees paid everything.
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6. Beginning in mid-2006, Signal, both via its own employees and via its external Agents, traveled to India in order to recruit workers, including each of the Plaintiffs. In printed advertisements and in-person meetings in India, Defendants promised Plaintiffs that in exchange for “recruitment fees” payable to the Agents ranging anywhere from the equivalent of $10,000 to $25,000, Defendants would provide Plaintiffs with jobs at Signal and assist them in applying for and receiving green cards.
7. Defendants told Plaintiffs that because the permanent residency process could take up to two years to complete and Signal’s need for workers was immediate, Defendants would first assist Plaintiffs in obtaining temporary work visas, known as H-2B visas, while simultaneously applying for green cards.
8. Lured by the promise of, in the words of one of the Defendants’ advertisements, the opportunity for “permanent lifetime settlement in the U.S.A. for self and family,” Plaintiffs took on immense burdens to gather enormous fees, often by selling family assets and incurring significant debt at usurious rates. Plaintiffs did this because they believed they would recoup the expense with the high wages they were promised at Signal, and through the long-term employment opportunities that would be available to them and their families as permanent residents of the United States.
9. In actuality, the Defendants’ promises regarding green cards for Plaintiffs were illusory. Defendants had not taken, and had no intention at that time of taking, any steps to assist the Plaintiffs in applying for or receiving green cards. To the contrary, Signal (with the knowledge and assistance of the Agents) represented to the United States government that it would employ the workers only temporarily, and that the workers would be returned to India
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“within the. . .year.” At no point did Signal or any of the Agents take any steps to assist any Plaintiff in applying for or receiving a green card.
10. Plaintiffs, of course, were never told of Signal’s representations to the United States government. The Plaintiffs were unaware that Defendants’ promises of employment and permanent residency were false and relied on these false promises to their detriment.
11. Put simply, Plaintiffs had been deceived into taking on life-altering debt for something that was never going to happen.
12. Upon arrival at Signal’s facilities in Mississippi, Plaintiffs’ plight only worsened. Signal utilized psychological abuse, coercion, and fraud to leave Plaintiffs afraid and unable to leave Signal’s facilities and employ. Plaintiffs were required to live in camps on Signal’s Pascagoula premises, enduring barbaric and prison-like conditions. Plaintiffs were among several hundred men crammed into trailer-like bunkhouses that were far too small for the number of men housed therein, and otherwise unfit for human habitation. Privacy was non-existent. Toilet and bathing facilities were insufficient. Food was often rotten. Private “security guards” patrolled the grounds like prison guards, prevented the Plaintiffs from leaving, and subjected the Plaintiffs to random searches of their persons and belongings.
13. Signal sought to deflect as much of the housing costs as possible onto the Plaintiffs. For the “privilege” of living in prison-like squalor, Signal deducted $35 per day from Plaintiffs’ paychecks, seven days a week, which constituted over 34% of the workers’ pre-tax earnings. When workers requested permission to live off-site, they were told by Signal that they could do so, but that Signal would continue to collect the $35 per day. This compulsory deduction essentially prohibited Plaintiffs from living in more humane conditions, lest their work
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become even less remunerative, and consequently their “recruiting fee” debt become even more crushing.
14. Non-Indian workers were not subjected to such squalid living conditions, degrading treatment, or extortionate room and board policies.
15. Plaintiffs were also made to work in unsafe working conditions that non-Indian workers were not subjected to, and were forced to endure regular anti-Indian invective from Signal personnel, along with threats that they would be arrested and deported if they did not do Signal’s every bidding. Indeed, Signal housed Plaintiffs in the so-called “man camps” so that they would not mix with the Pascagoula community. The Signal executive supervising the Pascagoula man camp referred to the facility—privately and in professional correspondence to other Signal employees—as “the Reservation,” a term adopted from Signal’s “shipyard folks.” Another Signal employee was more direct, promising Signal management on April 5, 2007 that if he were placed in charge of the man camp, he would not give in to the “misguided notion that some of these Indians can be reasoned with” but would instead “most defiantly [sic] go on a ‘rat hunt.’”
16. Signal even forced men of Sikh heritage to shave their beards upon arriving in the camp. Wearing of a beard is an extremely important religious tradition to Sikh men, and Signal’s coercion left the men, including Plaintiff Ranjit Singh, reduced to tears.
17. Conditions were so poor at Signal’s Pascagoula facility that, after just a couple of months, workers (including Plaintiffs) began to consider ways to convince Signal to improve conditions. In retaliation for the workers’ attempts to improve their lot, Signal terminated the employment of four of the most outspoken workers, forcibly removed them from the camp and told them they would be immediately returned them to India. One of those expelled men, so
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distraught over the thought of returning to India with the crushing debt of the “recruitment fees,” attempted suicide in front of one of the Plaintiffs.
18. Signal used this horrifying incident to its advantage. In a meeting with the workers (including the Plaintiffs) days after the attempted suicide, Signal told Plaintiffs that if any of the Signal workers filed a lawsuit against Signal, Signal would send all of the workers back to India. The Plaintiffs understood this to mean that they must remain quiescent and work, lest Signal retaliate and ruin them financially.
19. Signal employed other methods of forcing the Plaintiffs to endure the abusive conditions. In keeping with its focus on deflecting labor costs, upon Plaintiffs’ arrival, Signal required workers to set up “direct deposit” bank accounts with a local bank, to which Signal also had access. These accounts gave Signal control over the workers’ ability to leave the facility because Signal could threaten to cut off the workers’ access to the accounts at any point. Indeed, this is exactly what happened—in April, 2007, after certain workers fled the Pascagoula camp, those workers were denied access to their accounts, at the behest of Signal. This had the intended effect of intimidating and coercing the remaining workers, including Plaintiffs, into compliance.
20. Deeply indebted, fearful, isolated, disoriented, and unfamiliar with their rights under United States law, Plaintiffs felt compelled to continue working for Signal, on Signal’s onerous terms and in abusive conditions.
21. In line with Signal’s original intention as expressed to the United States government—but not to the Plaintiffs—to employ the workers temporarily, the vast majority of Plaintiffs were terminated within a year and a half of arriving in Pascagoula or left to escape the horrid conditions.
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22. At no point did Signal or the Agents ever apply for, or assist Plaintiffs in applying

for, permanent residency. Moreover, consistent with its never-failing effort to improve its

bottom line by transferring as many costs associated with their employment as possible back

onto Plaintiffs, Signal never refunded the tens of thousands of dollars in “recruitment fees”

Plaintiffs had paid in exchange for less than one year of low-paid work. None of the Plaintiffs

earned enough money at Signal to make the exorbitant and debt-inducing “recruitment fees”

even remotely worthwhile. Moreover, Signal never compensated Plaintiffs in any way for the

physical, emotional, and psychological degradations inflicted upon them at the Pascagoula camp.

23. In short, and as will be alleged more fully below, Defendants’ promises of

employment-based green cards were fictional:

•

Defendants never filed or otherwise supported green card applications for

Plaintiffs, or took any other steps toward assisting Plaintiffs with securing

green cards;

•

Defendants told United States Department of Homeland Security under

penalty of perjury that Signal’s need for workers was temporary;

•

Signal has stated in court filings that it never intended to provide the

workers with green cards, but rather with temporary H-2B visas;

•

Defendants segregated and confined Plaintiffs and other Indian workers to

the man camp because Defendants did not want Indian workers mixing

with other members of the Pascagoula community; and

•

Internal correspondence among Signal management in May 2006 shows

that “[a]ll [Signal is] doing now is bringing the workers in under the H2B

program.”

Defendants’ Conduct Violated Congress’s Clear Prohibition Against Human Trafficking 24. In 2000, Congress enacted the Victims of Trafficking and Violence Protection Act

to provide enhanced legal protections for victims of human trafficking and to supplement

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existing forms of relief. Congress specifically included protections for persons forced to work out of fear of serious harm, physical restraint, abuse of the legal process, or threats of the same.
25. According to House Report 106-939, the new statute was “intended to address the increasingly subtle methods of traffickers who place their victims in modern-day slavery, such as where traffickers threaten harm to third persons, restrain their victims without physical violence or injury, or threaten dire consequences by means other than overt violence.” In particular, Congress clarified that the statute covered “a broad array of harms, including both physical and nonphysical,” and could apply where the perpetrator “intentionally caus[ed] the victim to believe that her family [would] face harms such as banishment, starvation, or bankruptcy in their home country.”
26. In 2003, Congress amended the statute to permit individual victims of trafficking to bring civil claims against their traffickers. Plaintiffs do so here. Plaintiffs also bring claims for violations of fraudulent misrepresentation, negligent misrepresentation, and breach of contract against all Defendants and for violations of the Civil Rights Act of 1866 against Signal.1

1

Plaintiffs Lakshmanan Ponnayan Achari, Kodakeril Baby Biji, Xavier Disoliyan, Rajankunju

Geevarghese, Jomon George, Shaiju Vadakkal George, Mouleswararao Guntamukkala, Joy

Jacob, Biju John, Shibu Joseph, Raveendranathan Mookaparambil Itty, Sunilkumar Marottikkal

Kuttan, Parshottam Ramchandra Mangani, Prakash Moses Kanagiah Manonmoni, Adharsan

Manuel, Jacob Mazhukkattu Mathew, Johny Mathew, Nandhakumar Nagaraj, Shaji

Veluthalakuzhiyil Nanoo, Mangalan Chandrasekharan Pillai, Radhakrishna Pillai Sivarama Pillai,

Aby Molathu Poulose, Justin Poulose, Appunni Arul Prakash, Sreenivasarao Raparthy, Balwinder

Singh, Ranjit Singh, Shanmugam Subramanian, Ninan John Tharakan, George Pulikkeparambil

Varghese, Benny Kattukariyil Varkey, Shahi Vijayan, and John Yohannan (collectively, the

“Original Plaintiffs”) maintain their claims against Defendant Michael Pol, who filed a petition

for Chapter 7 bankruptcy on June 13, 2013, after the Original Plaintiffs filed their Complaint.

Plaintiffs Varghese Varkey Abraham, Subhashithan Bahuleyan, Praveen Kulathum Muriyil Gopalakrishnan, Eldose Isac, Thansilas Joseph, Kulath Somanathan Kalayam, Bhaskaran Sreedharan Kutty, Nibu Raju, Savinder Singh, Kittayi Sunil Kumar Therattil, Moni Panikulangara Thomas, Thenooran Kumaran Unnikrishnan, Benny Chittilappilly Vareed, and the Estate of Kuliyanickal Paily Varghese (collectively, the “Amended Plaintiffs”) do not bring claims against Michael Pol, although they maintain their claims against Global Resources, Inc.

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JURISDICTION AND VENUE 27. This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C. § 1331 (federal question jurisdiction), 18 U.S.C. § 1595(a) (civil trafficking), 28 U.S.C. § 1343 (civil rights), and 28 U.S.C. § 1367 (pendent state law claims). 28. This Court has personal jurisdiction over Signal pursuant to Fed. R. Civ. P. 4(k) and Miss. Code § 13-3-57 as Signal maintains a continuing business presence in the state, including but not limited to two shipyards in Pascagoula, Mississippi, where Plaintiffs worked and most of the wrongful conduct alleged herein occurred. This Court also has personal jurisdiction under Fed. R. Civ. P. 4(k) and Miss. Code § 13-3-57 over Pol, a resident of Mississippi; Global Resources, Inc., which is incorporated under the laws of Mississippi; Burnett, who is registered to vote and practices law in Mississippi; and the Law Offices of Malvern C. Burnett and Gulf Coast Immigration Law Center, LLC, which have offices in Ocean Springs, Mississippi and where much of the legal work alleged herein was performed. This Court has personal jurisdiction over Dewan and Dewan Consultants Pvt. Ltd. under Fed. R. Civ. P. 4(k) and Miss. Code § 13-3-57. Dewan Consultants Pvt. Ltd. contracted with Pol and Burnett and served as Signal’s agent to recruit workers and deliver them for employment in Mississippi. Dewan, both individually and on behalf of Dewan Consultants Pvt. Ltd., traveled to Pascagoula, Mississippi, in connection with the events described herein. 29. Venue is proper in this district under 28 U.S.C. § 1391 in that much of Defendants’ trafficking activity, civil rights violations, fraud, misrepresentations, and breach of contract occurred within this judicial district.
PARTIES
Claims against Pol are stayed by the bankruptcy proceeding, and the Amended Plaintiffs joined an Amended Complaint filed after Pol’s bankruptcy petition.
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Plaintiffs 30. All Plaintiffs are Indian nationals, of Indian race and ethnicity, and former H-2B guest workers who were recruited from India by Defendants in or about 2006 and worked at Signal’s Pascagoula, Mississippi facility after arriving in the United States. Plaintiffs each paid the Agents the equivalent of between $10,000 and $25,000 in “recruitment fees” based on the false promise that they would assist them in applying for and receiving green cards. Plaintiffs were each subjected to discriminatory, dangerous, and abusive treatment upon their arrival at Signal. 31. Plaintiff Lakshmanan Ponnayan Achari was recruited beginning in or about April of 2006 and arrived in the United States on or about December 5, 2006. 32. Plaintiff Varghese Varkey Abraham was recruited beginning in or about May of 2006 and arrived in the United States on or about November 28, 2006. 33. Plaintiff Kodakeril Baby Biji was recruited beginning in or about July of 2006 and arrived in the United States on or about December 5, 2006. 34. Plaintiff Subhashithan Bahuleyan was recruited in or about and between February and June of 2006 and arrived in the United States on or about November 27, 2006. 35. Plaintiff Xavier Disoliyan was recruited beginning in or about June and July of 2006 and arrived in the United States on or about November 20, 2006. 36. Plaintiff Rajankunju Geevarghese was recruited beginning in or about April of 2006 and arrived in the United States on or about November 28, 2006. 37. Plaintiff Jomon George was recruited beginning in or about April or May of 2006 and arrived in the United States on or about November 28, 2006. 38. Plaintiff Shaiju Vadakkal George was recruited beginning in or about April and May of 2006 and arrived in the United States on or about November 28, 2006. 10

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39. Plaintiff Praveen Kulathum Muriyil Gopalakrishnan was recruited beginning in or about June of 2006 and arrived in the United States on or about November 20, 2006.
40. Plaintiff Mouleswararao Guntamukkala was recruited beginning on or about May 23, 2006 and arrived in the United States on or about January 24, 2007.
41. Plaintiff Eldose Isac was recruited beginning in or about May of 2006 and arrived in the United States on or about November 23, 2006.
42. Plaintiff Raveendranathan Mookaparambil Itty was recruited beginning in or about late 2005 and arrived in the United States on or about December 1, 2006.
43. Plaintiff Joy Jacob was recruited beginning in or about the summer of 2006 and arrived in the United States in or about late 2006.
44. Plaintiff Biju John was recruited beginning in or about April or May of 2006 and arrived in the United States on or about November 20, 2006.
45. Plaintiff Shibu Joseph was recruited beginning in or about April or May of 2006 and arrived in the United States on or about November 28, 2006.
46. Plaintiff Thansilas Joseph was recruited beginning in or about June of 2006 and arrived in the United States on or about December 5, 2006.
47. Plaintiff Kulath Somanathan Kalayam was recruited beginning in or about June of 2006 and arrived in the United States on or about December of 2006.
48. Plaintiff Sunilkumar Marottikkal Kuttan was recruited in beginning in or about May or June of 2006 and arrived in the United States on or about December 7, 2006.
49. Plaintiff Bhaskaran Sreedharan Kutty was recruited beginning in or about May of 2006 and arrived in the United States on or about December 18, 2006.
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50. Plaintiff Parshottam Ramchandra Mangani was recruited beginning in or about April or July of 2006 and arrived in the United States on or about November 6, 2006.
51. Plaintiff Prakash Moses Kanagiah Manonmoni was recruited beginning in or about July of 2006 and arrived in the United States on or about November 28, 2006.
52. Plaintiff Adharsan Manuel was recruited beginning in or about June of 2006 and arrived in the United States on or about November 16, 2006.
53. Plaintiff Jacob Mazhukkattu Mathew was recruited beginning in or about June or July of 2006 and arrived in the United States on or about December 7, 2006.
54. Plaintiff Johny Mathew was recruited beginning in or about March of 2006 and arrived in the United States on or about November 29, 2006.
55. Plaintiff Nandhakumar Nagaraj was recruited beginning in or about May or June of 2006 and arrived in the United States on or about November 26, 2006.
56. Plaintiff Shaji Veluthalakuzhiyil Nanoo was recruited beginning in or about April or May of 2006 and arrived in the United States on or about November 28, 2006.
57. Plaintiff Mangalan Chandrasekharan Pillai was recruited beginning in or about June 2006 and arrived in the United States on or about November 20, 2006.
58. Plaintiff Radhakrishna Pillai Sivarama Pillai was recruited beginning in or about May of 2006 and arrived in the United States on or about November 19, 2006.
59. Plaintiff Aby Molathu Poulose was recruited beginning in or about March or April of 2006 and arrived in the United States on or about November 18, 2006.
60. Plaintiff Justin Poulose was recruited beginning in or about the summer of 2006 and arrived in the United States on or about November 20, 2006.
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61. Plaintiff Appunni Arul Prakash was recruited beginning in or about April or May of 2006 and arrived in the United States on or about November 27, 2006.
62. Plaintiff Nibu Raju was recruited beginning in or about May or June of 2006 and arrived in the United States on or about November 29, 2006.
63. Plaintiff Sreenivasarao Raparthy was recruited beginning on or about June 26, 2006 and arrived in the United States on or about November 29, 2006.
64. Plaintiff Balwinder Singh was recruited beginning in or about 2006 and arrived in the United States in or about 2006.
65. Plaintiff Ranjit Singh was recruited beginning in or about May or June 2006 and arrived in the United States on or about October 30, 2006.
66. Plaintiff Savinder Singh was recruited beginning in or about April or May of 2006 and arrived in the United States on or about October 30, 2006.
67. Plaintiff Shanmugam Subramanian was recruited beginning in or about April of 2006 and arrived in the United States on or about November 28, 2006.
68. Plaintiff Ninan John Tharakan was recruited beginning in or about May of 2006 and arrived in the United States on or about November 26, 2006.
69. Plaintiff Kittayi Sunil Kumar Therattil was recruited beginning in or about July of 2006 and arrived in the United States on or about December 6, 2006.
70. Plaintiff Moni Panikulangara Thomas was recruited beginning in or about May of 2006 and arrived in the United States on or about November 23, 2006.
71. Plaintiff Thenooran Kumaran Unnikrishnan was recruited beginning in or about June of 2006 and arrived in the United States on or about November 28, 2006.
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72. Plaintiff Benny Chittilappilly Vareed was recruited beginning in or about May of 2006 and arrived in the United States on or about November 19, 2006.
73. Plaintiff George Pulikkeparambil Varghese was recruited beginning in or about August of 2006 and arrived in the United States on or about January 24, 2007.
74. Kuliyanickal Paily Varghese, who is deceased and whose interests are pursued by Plaintiff Estate of Kuliyanickal Paily Varghese, was recruited beginning in or about June of 2006 and arrived in the United States on or about November 27, 2006.
75. Plaintiff Benny Kattukariyil Varkey was recruited beginning in or about February or March of 2006 and arrived in the United States on or about November 28, 2006.
76. Plaintiff Shahi Vijayan was recruited beginning in or about March or April of 2006 and arrived in the United States on or about November 20, 2006.
77. Plaintiff John Yohannan was recruited beginning in or about May of 2006 and arrived in the United States in or about November of 2006.
Defendants 78. Defendants Signal International, LLC and Signal International, Inc. are corporations organized under the laws of Delaware, with facilities in the Gulf Coast region, including Pascagoula, Mississippi. At all relevant times, Signal International, LLC acted as an agent and/or alter ego of Signal International, Inc., and took all conduct discussed herein with the knowledge and consent of Signal International Inc. Signal International, LLC and Signal International, Inc. will be referred to collectively below as “Signal” unless a distinction is drawn between them. Signal provides marine and fabrication services, including offshore drilling rig overhaul, repair, upgrade and conversion. 79. Defendant Global Resources, Inc. (“Global”) is a corporation organized under the laws of Mississippi that recruits workers from India for employment in the United States. 14

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80. Defendant Michael Pol (“Pol”) was, at all relevant times, the President of Global Resources, Inc., and resides in Mississippi. On information and belief, Pol was, at all relevant times, the sole corporate officer of Global. Pol and Global Resources, Inc. are alter egos. Global and Pol will be referred to collectively below as “Pol,” unless a distinction is drawn between them.
81. Defendant Dewan Consultants Pvt. Ltd. (a/k/a Medtech Consultants) (“Dewan Consultants”) is a private limited liability company organized under the laws of India. Dewan Consultants has substantial business contacts with Pascagoula, Mississippi. In 2004, Dewan Consultants contracted with Global and Burnett—through the Gulf Coast Immigration Law Center, LLC—to identify and recruit Indian workers for employment in the United States on permanent residency visas.
82. Defendant Sachin Dewan (“Dewan”) is the Director of Dewan Consultants. Dewan resides in India and has, since at least 2005, had substantial business contacts with Pascagoula, Mississippi, including travel to Pascagoula on behalf of Signal and Dewan Consultants. Dewan and Dewan Consultants will be referred to collectively below as “Dewan,” unless a distinction is drawn between them.
83. Defendant Malvern C. Burnett (“Burnett”) is an attorney who is registered to vote in Mississippi and maintains offices in Ocean Springs, Mississippi. Burnett used his Ocean Springs office to perform much of the legal work necessary to bring Plaintiffs and other Indian workers to the United States on H-2B visas.
84. Defendant Law Offices of Malvern C. Burnett, A.P.C. (“Burnett Law Offices”) is a professional law corporation organized under the laws of Louisiana that maintains offices in Ocean Springs, Mississippi.
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85. Defendant Gulf Coast Immigration Law Center, LLC (“Gulf Coast Immigration”) is a limited liability corporation organized under the laws of Louisiana that maintains offices Mississippi. Burnett is the registered agent of Gulf Coast Immigration. On information and belief, Burnett is the sole member and/or corporate officer of Gulf Coast Immigration. Burnett, the Burnett Law Offices and Gulf Coast Immigration operated as a joint venture and/or alter egos, and will be referred to collectively below as “Burnett,” unless a distinction is drawn between them.
86. At all relevant times, the Agents acted as the agents and/or representatives of Signal, and were acting within the course and scope of their agency, with the full knowledge, consent, permission, authorization and ratification, either express or implied, of Signal in performing the acts alleged in this complaint.
87. At all relevant times, the Agents were involved in a venture with each other to recruit the Indian workers, including the Plaintiffs, and bring them to the United States to work at Signal, as memorialized by various oral and written communications and agreements, and were acting within the course and scope of that venture and those agreements, with the full knowledge, consent, permission, authorization and ratification, either express or implied, of each of the other Agents in performing the acts alleged in this complaint.
SUBSTANTIVE ALLEGATIONS In the Aftermath of Hurricane Katrina, Signal Contracts with Dewan, Burnett, and Pol to
Bring Temporary Workers to the United States at No Cost to Signal 88. The devastation caused by Hurricane Katrina presented both an opportunity and a challenge for Signal. The rebuilding effort offered significant potential for new work fixing damaged oil rigs, ships, and other marine platforms. At the same time, however, because the
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hurricane also destroyed or damaged thousands of homes along the Gulf Coast, including in Pascagoula, some of Signal’s workforce had temporarily left the area.
89. In early 2006, Michael Pol approached Signal with a purported solution to its problem. At a meeting in January or February of 2006, Pol told Signal’s Chief Financial Officer Chris Cunningham, Senior Vice President and General Manager Ronald Schnoor, and Vice President of Productions for Mississippi Operations Bill Bingle, that he could deliver first-class fitters and welders from India at no cost to Signal. Pol informed Signal that he would work with local immigration attorney Burnett and India-based recruiter Dewan to bring skilled welders from India. The workers themselves would pay for all costs and fees associated with the recruitment process, immigration processing, and travel to the United States, and Signal would not reimburse the workers for these fees. Signal would pay the workers between $14 and $18 per hour, depending upon skill level.
90. On April 18, 2006, Signal executed a document entitled “Skilled Worker Recruitment Agreement” (the “Recruitment Agreement”) with Pol’s company, Global, authorizing Global to recruit foreign skilled workers for employment at Signal “under the ‘H-2B’ temporary program and/or the ‘permanent residence’ process.” Pursuant to the Recruitment Agreement, Global would be responsible for all costs associated with recruitment, transportation, and entry of the foreign workers into the United States and would deliver the workers “at no cost to Signal” to the airport of Signal’s choice. The cost incurred by Pol would be deducted directly from the foreign workers’ wages and paid to Pol/Global.
91. On June 19, 2006, Signal executed a power of attorney with Dewan’s company, Dewan Consultants, appointing Dewan Consultants as Signal’s “representative in India to facilitate the recruitment of skilled workers to the United States of America” for employment at
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Signal. The power of attorney authorized Dewan Consultants to advertise, conduct seminars and trade tests, and sign any necessary legal documentation on Signal’s behalf.
92. Also in mid-2006, Signal entered into an attorney-client relationship with Burnett to advise Signal on immigration issues pertaining to Signal’s need for workers. Signal and Burnett later memorialized their engagement in a written retainer agreement. Pursuant to that agreement, Signal would not be responsible for any of Burnett’s legal fees. Rather, under the terms of the agreement, Burnett took funds from the “recruitment fees” charged to the workers to pay for the legal services he provided to Signal.
Defendants File Petitions for Temporary H-2B Visas, Not Green Cards 93. Signal requested that the Agents secure foreign workers and transport them to the United States as quickly as possible. Signal and the Agents decided that Signal would sponsor workers on an H-2B visa, which could later be extended if Signal needed more foreign labor. 94. In 2006, Dewan and Burnett placed newspaper advertisements in at least six Indian cities to recruit workers for Signal. Some of the advertisements offered welders and fitters opportunities to go to the United States and obtain H-2B visas or “Employment Based Green Cards.” Other advertisements touted the opportunity for “permanent lifetime settlement in U.S.A. for self and family.” 95. In the spring, summer, and fall of 2006, Dewan, Pol, and Burnett traveled multiple times to India and the United Arab Emirates (“UAE”) to conduct recruitment seminars with interested potential workers. Several Signal employees, including Signal Special Projects Manager John Sanders and Vice-President of Productions for Mississippi Operations William Bingle, traveled to India and attended these sessions. Sanders also oversaw the immigration interviews and served as contact between Signal and consular officials.
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96. At these various seminars, the Agents promised recruits, including Plaintiffs, that Signal would sponsor green card applications for them. In their seminar presentations, the Agents promised that although all hopeful green card applicants would automatically be enrolled as H-2B candidates, this would not affect the employment-based green card process.
97. Written agreements between Plaintiffs and the Agents also explicitly promised assistance in applying for and securing green cards—assistance that Defendants took no steps toward providing. Dewan Consultants had some Plaintiffs sign “memoranda of understanding,” which, among other things, informed the workers that “Signal International, LLC has orally promised the Facilitator [Dewan Consultants] . . . that . . . [Signal] will be willing to file and process their employment base [sic.] Green Card.” Dewan Consultants also issued form letters to some Plaintiffs, informing them that Signal “shall proceed with your Green Card for United States of America.” Likewise, the Burnett Law Offices and Gulf Coast Immigration signed receipts memorializing the payment of “Part Fees for Employment Based Permanent Residence Visa Processing for Signal International,” and Global issued a “Services Agreement” promising some Plaintiffs that Global would do “everything within its power to assist worker to obtain permanent residence status in the United States within 24 months.”
98. Signal and its Agents told the Plaintiffs that Signal would sponsor them immediately for green cards in order to induce them to pay large fees to travel to the United States—which had the net effect of defraying nearly all the costs Signal would have had to expend to recruit workers legitimately—and to induce them to pay exorbitant “recruitment fees” far in excess of what would actually be required by the Defendants to obtain H-2B visas or even the promised green cards.
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99. Unbeknownst to the Plaintiffs, however, Defendants did not take any steps to apply for permanent residence for the Plaintiffs. Defendants only helped Plaintiffs obtain temporary H-2B visas that legally prevented Plaintiffs from working for any United States employer besides Signal. Indeed, Signal made clear in its application to the United States Department of Homeland Security that its need for workers was temporary and short-lived.
100. To ensure that their deception remained hidden, Defendants instructed Plaintiffs not to tell United States Department of Homeland Security officials during their forthcoming H2B visa interviews that, in addition to applying for temporary worker status, Signal had promised them that it would sponsor them for green cards. As Pol explained to Sanders in an August 24, 2006 email:
Mal[vern Burnett], Sachin [Dewan] or I[ ] needs to be with each and every candidate going into the consulates before their interview [because] [t]hey sometimes say the dumbest things and need to be coached on the proper way to interview. . . . [T]here are some things that should not be known to the consulate personnel, such as the fact that we are going to process them for a green card. If one of those guys says he is going to the U.S. for immigration and Signal is sponsoring him for permanent residence (green card) . . . he is a goner. Plaintiffs Incur Substantial Debt to Afford High “Recruitment Fees” 101. Lured by the Agents’ promises of high-paying employment and permanent residency in the United States, Plaintiffs relinquished stable employment opportunities in India and as guest workers in the Persian Gulf. 102. Apart from foregoing additional financial gains, Plaintiffs also sold personal and familial assets and incurred substantial debt to afford the fees demanded by Defendants for their recruitment and travel to the United States. 103. These fees, quoted in various amounts to Plaintiffs, ranged from the equivalent of approximately $10,000 to $25,000. 20

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104. The Agents knew that these fees would cause the workers, including Plaintiffs, to incur substantial and potentially ruinous debt.
105. Each Plaintiff paid the amounts Defendants requested, as detailed in further allegations below.
106. Before receiving their visas, Plaintiffs were interviewed by officials at the U.S. consulate in India. Prior to these interviews, Dewan and other employees of Dewan Consultants met with Plaintiffs, took their passports, collected payments for the consular interviews, and, at the direction of Burnett, instructed them to tell consular officials that they only paid a total of approximately $670 in recruiting and immigration processing fees.
107. Dewan told Plaintiffs that if they told the truth about the significant fees they had paid, their visas would be cancelled and the Agents would keep the money they had already collected.
108. Even in the face of significant delays in processing immigration paperwork, which left the Plaintiffs jobless and uncertain of their futures, Dewan, Pol, and Burnett refused to refund any fees for any reason. When certain Plaintiffs, including Shaiju Vadakkal George and Aby Molathu Poulose, expressed reluctance to continue with the immigration process or pay the next fee installment, Dewan, Pol, and Burnett threatened forfeiture of all money paid to that point. Defendants also loaded new, unexplained fees onto the workers, from minor fees (such as $45 “testing fees”) to significant additional last-minute travel expenses.
109. In the hours before their flights to the United States departed, Plaintiffs were required to wait in line to proceed through Dewan Consultants’ cramped offices to make a final installment payment in cash. Dewan then forced Plaintiffs to sign various documents—many written in English, which certain of the Plaintiffs could not read or understand—in a rushed
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fashion. Dewan warned Plaintiffs that they would miss their flights if they did not sign quickly. He even refused to tell Plaintiffs what it was they were signing. Only after Plaintiffs signed the documents did Dewan return their passports to them.
110. Thereafter, each Plaintiff boarded a flight to the United States, where they were picked up from the airport by Signal personnel and taken to Signal’s Pascagoula, Mississippi facility.
Plaintiffs Arrive in Signal’s Pascagoula, Mississippi Man Camp and are Subjected to Degrading and Discriminatory Conditions
111. Signal assigned each Plaintiff to work at its Pascagoula, Mississippi fabrication facility.
112. Signal required that each Plaintiff live in a man camp constructed in the fall of 2006 specifically to house Indian workers. Signal employees and management referred to the Pascagoula man camp as “the Reservation.”
113. Signal personnel discussed among themselves, including in written email communications, that housing the workers in a secluded man camp on the outskirts of town was preferable, as it would keep the Indians segregated from the rest of the Pascagoula, Mississippi community.
114. The Pascagoula man camp was isolated, over-crowded, unsanitary, and not suitable for human habitation. Workers were not permitted to photograph the man camp.
Overcrowded Bunkhouses 115. The camp bunkhouses themselves were not fit for long-term human habitation. Signal crammed up to twenty-four men into each bunkhouse. The bunk beds were so tightly packed that it was difficult for the Plaintiffs to move between them. The top bunks were so close
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to the ceiling and the bottom bunks so close to the top bunks that Plaintiffs could barely sit up in their beds.
116. The bunkhouses had insufficient toilet and showering facilities. Lines for the bathroom were consistently very long. The showers themselves were dangerous. Electrical conduit joints near the showers were unglued, exposing workers to potential electrocution.
117. Privacy was impossible, and sleep was difficult, due to the noise from such close quarters, oppressive smells, and the comings and goings of workers who worked on different shifts. Some workers reported rats in their sleeping areas. Occasionally, rats ran across their bodies.
118. These conditions fell far short of basic requirements of habitability. For example, the federal government’s Occupational Safety and Health Administration (“OSHA”) guidelines state that bunkhouses of similar purpose should have a minimum of 50 square feet of floor space per habitant. Signal’s bunkhouses offered less than 18 square feet of floor space per worker. Likewise, OSHA guidelines require bunk beds to be at least 48 inches apart from other beds. Signal’s bunk beds were so tightly packed together that workers were essentially sleeping next to each other.
119. Workers told Signal personnel on numerous occasions that they found these conditions to be intolerable. Internal communications among Signal personnel discussed the “overcrowding,” acknowledging that the Pascagoula camp was at least “3 bunk-houses” shy of appropriate capacity, and that “more toilet/sink capacity” was needed.
Rotten Food 120. The food provided by Signal was deplorable. Meals were offered exclusively in a mess hall, which was only open during limited hours. Workers who showed up a few minutes
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late for a meal were denied food altogether. Those who did eat were often served rotten food and, at times, workers found bugs in their meals.
121. Plaintiffs frequently complained to Signal personnel that the food was so bad that they were left hungry. Many became physically ill or suffered chronic gastric problems, conditions that they made known to Signal.
122. In an email to other Signal personnel, Signal Senior Vice-President & General Manager Ron Schnoor acknowledged the “bad, stale, molded, and otherwise poor quality food.”
Rampant Disease 123. Even apart from the kitchen conditions, the man camp itself was a breeding ground for bacteria and disease. 124. Workers frequently became severely ill. As explained by the Signal’s manager of the Pascagoula man camp:
Our Indians have been dropping with sickness like flies. . . . [They] are getting w orried a nd believe there are unhealthful conditions in the cam p. It is true. The reaso n is because the plumbing was so shoddily done by GE’s subcontractors, and water has leaked everywhere and stagnate d as a result, which serves as a bacterial breeding ground.
Perpetual and Abusive Oversight 125. Signal instilled in Plaintiffs a climate of fear through perpetual and invasive oversight and surveillance. 126. The Pascagoula man camp was located in an isolated industrial area that was miles removed from other residential communities, shopping facilities, worship houses, and other basic amenities. The man camp was enclosed by fences and accessible only by a single entrance, which was guarded by an armed security guard at all times. When returning “home” from work and entering the camp, Plaintiffs were required to show identification and subject
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themselves and their belongings to search. Their movements into and out of the camp were logged.
127. Guests were not normally permitted in the man camp. Plaintiffs were permitted visitors in the parking lot.
128. Because the camp was isolated, Plaintiffs relied upon transportation from Signal to and from work and also to other populated areas. However, Signal would only take them to Wal-Mart or the bank. Even then, Plaintiffs had little privacy as Signal security would occasionally follow them into Wal-Mart.
129. Signal’s private security forces entered the Plaintiffs’ bunk areas at night. Signal personnel and camp security guards conducted “surprise searches” of the bunkhouses, including searches of workers’ personal belongings.
130. Plaintiffs were not told when these searches would be conducted (again, in what was supposed to be Plaintiffs’ “home”), nor were they apprised of what it was Signal was looking for.
131. Signal prohibited Plaintiffs from drinking alcohol at the camp. Violations subjected the workers to fines of $250 and suspension from work. A second “offense” would result in a $500 fine; a third “offense,” $750.
132. The prohibition of alcohol was modeled after Signal’s policies for conduct in the workplace despite the fact that the workers were living, not working, in the man camp.
133. Signal did not bar its non-Indian workers from having visitors or drinking alcohol in their homes. Nor did Signal confine its non-Indian workers to crowded bunkhouses or subject them to invasive searches of their homes or belongings and near-constant surveillance.
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Signal Charged Plaintiffs Approximately $1,050 Each Month to Live in These Conditions 134. For the “privilege” of living in these conditions, the Indian workers (including
each Plaintiff) were charged $35 dollars per day (approximately $1,050 per month). From this amount, $21 was allocated towards rent and $14 towards food. The $35 daily fee was deducted automatically from the Plaintiffs’ paychecks.
135. Pol personally received $1.50 per day per worker from the $14 food cost in pure profit for having referred a caterer, Laxmi Catering, to Signal. When Pol was later terminated by Signal, the $1.50 per worker per day profit was not remitted to the workers but was instead paid to another caterer, Anjay Keswani.
136. Before the $35 per day value was set, Signal’s Senior Vice President and General Manager Ronald Schnoor initially recommended that Signal charge the workers $53.50 per day. Schnoor reached that figure by calculating the amount it would take to amortize over just ten months the entire cost Signal incurred building the man camps in Pascagoula, Mississippi, and Orange, Texas—a $7 million capital expenditure. Schnoor shockingly dismissed the devastating impact of this exorbitant $1,600 per month fee by cavalierly asserting that the Plaintiffs and their fellow workers would all be “happy campers” because Signal’s living arrangements and wages were likely to be an improvement over conditions in India.
137. After a short time in the camp, workers (including certain Plaintiffs) began complaining about the poor conditions and asked to live outside the camp in accommodations of their own choosing. In response, Signal informed Plaintiffs that if they tried to live outside the camps, Signal would continue to deduct $35 per day from their paychecks. Given their substantial debts, this wage deduction left Plaintiffs with no choice but to remain at the camp.
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138. Signal did not require any non-Indian workers to pay for Signal’s capital expenditures, nor did it require any other workers to pay for living expenses, whether or not they were living in Signal-provided housing.
139. Signal imposed this onerous policy in order to avoid paying any of its own expenses. By exploiting the Plaintiffs’ tenuous financial position, heavy debt load, precarious immigration situation and fear of job loss, Signal knew that they and their coworkers would have no choice but to continue working at the company. Indeed, because of the grip in which Signal held its Indian workers, the Plaintiffs felt compelled to remain at the Pascagoula man camp.
140. In contrast, workers of non-Indian race, ethnicity, or alienage were not required, or even allowed, to live in and/or pay for housing in the Pascagoula man camp.
Plaintiffs Experienced Other Discrimination by Signal and its Employees Due to their Race, Ethnicity, Religion, and Alienage
141. Defendants’ racial animus and discrimination against Plaintiffs and the other Indian workers took other, equally abusive, forms.
142. Signal employees ridiculed Plaintiffs and accused Indians of being dirty people who did not bathe. Whether on “the Reservation” or at the worksite, Signal employees, including supervisors, repeatedly referred to Plaintiffs and the other Indian workers as “animals,” “Indian pigs,” or similarly offensive and racist slurs. Signal supervisors laughed when Plaintiffs’ non-Indian co-workers harassed them.
143. Management frequently referred to Plaintiffs by badge number, even though they called non-Indian workers by their given names. Some Plaintiffs were also referred to by offensive nicknames. For example, Plaintiff Thenooran Unnikrishnan was referred to by Signal managers as “Raccoon,” because they said his name was too hard to pronounce.
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144. In an April 5, 2007 email to Signal employees Bill Bingle and Tracey Binion, Signal employee Darrell Snyder stated his opinion that it was a “misguided notion that some of these Indians can be reasoned with,” and discussed his plan to engage in a “rat hunt” in the Pascagoula camp to determine who was causing “dissension” among the workers.
145. Signal also displayed a shocking lack of respect for Plaintiffs’ religious beliefs. 146. Signal knew that many of the workers were highly religious. In particular, Signal knew that certain of its workers were Sikh. 147. Wearing a beard is an article of faith in Sikhism. In the Sikh tradition, a beard demonstrates a love of God and respect for the natural form God bestows on man. 148. Signal nevertheless demanded that Sikh workers shave their beards after arriving at the Pascagoula camp and threatened to deport them if they would not do so. When Plaintiff Ranjit Singh and other Sikhs were forced to shave their beards, they sat on the floor and cried, distraught. Workers of non-Indian race, ethnicity, or alienage and not of the Sikh religion were not subject to similar treatment. Signal also did not take any steps to provide reasonable accommodations to company policies or practices for its Sikh employees. 149. In addition, Signal knew that many of the workers were Hindu, but it treated Plaintiffs who practiced Hinduism differently than its Christian workers. Hindu Plaintiffs found it very difficult to pray in their living quarters due to the lack of space, but Signal did not provide any alternative areas for them to pray. Moreover, while Signal provided transportation to a local Christian church, Signal refused certain Plaintiffs’ request that it provide transportation to a Hindu temple. Signal employee John Sanders even required certain Hindu workers, including Plaintiff Thenooran Unnikrishnan, to attend a Christian church.
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150. Signal also required Plaintiffs to engage in repeated “skills testing” evaluations that non-Indian workers were not required to take and subjected Plaintiffs to on-the-job discipline, periods without work, lower pay, and unfavorable job assignments to which workers of non-Indian race, ethnicity, or alienage were not subjected. For example, when Indian workers finished their assignments early, Signal required them to do extra janitorial work. Non-Indian workers were allowed to remain idle. In addition, Signal managers controlled and closely monitored Plaintiffs’ bathroom breaks, while non-Indian workers were free to use the bathroom whenever they pleased.
151. Signal also forced Indian workers, including Plaintiffs, to perform tasks that were more difficult and more dangerous than the jobs Signal assigned to non-Indian workers. For instance, Signal made the Indian workers work in poorly lit oil rig tanks that contained powerful chemical fumes and lacked proper ventilation. Signal also required Plaintiffs to work on shoddily-built scaffolding. Non-Indian workers were not required to work in the oil rig tanks or under similar dangerous conditions.
152. Many Plaintiffs suffered injuries as a result of these and other unsafe conditions. Nonetheless, Signal refused them access to proper medical care. Signal knew that the conditions at the Signal man camp and work site rendered Plaintiffs reliant on Signal for transportation to care providers. But when Plaintiffs were injured, Signal refused to transport them. For example, in or about January 2007, Plaintiff Johny Mathew fell from a scaffold when the platform broke. He suffered chest pains, but Signal refused to take him to a doctor. It was only one or two days later, after Mathew’s symptoms persisted, that a Signal security officer took him to the hospital. At the hospital, the security officer told Mathew not to speak to the doctors and informed them that Mathew had fallen in the bathroom. Similarly, Plaintiff Thenooran
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Unnikrishnan suffered a head injury when he was struck with a pipe. Instead of treating his injuries, and despite the fact that his head was still bleeding, the Signal medic tested Unnikrishnan for the presence of drugs and alcohol in his bloodstream and then sent him back to work. When non-Indian workers suffered similar injuries, they were given proper medical treatment, were not forced to take tests for substance abuse, and were given time to recover.
153. When Plaintiffs complained about the unsafe and illegal working conditions, Signal forced them to do additional cleanup work, demoted them, suspended them without pay, and/or threatened to deport them. Plaintiff Parshottam Mangani was demoted after complaining about slippery floors at his worksite, while other Indian workers who complained about unsafe conditions were suspended for three days for “safety violations.” Workers of non-Indian race, ethnicity, or alienage were not treated this way.
154. Defendants’ discriminatory treatment of Plaintiffs and other Indian workers was motivated by racial, ethnic, and religious animus, as well as an animus against those of Indian national origin.
Signal and the Agents Continued to Mislead the Plaintiffs About the Terms of their Employment
155. On numerous occasions during October, November, and December 2006, Burnett and Signal personnel met with workers who asked about the prospect of receiving green cards. During these meetings, Signal personnel were told by workers that the Agents and Signal personnel in India had promised that Signal would apply for and help the workers obtain green cards, and that the workers had paid as much as $25,000 for that opportunity.
156. Rather than tell the workers honestly that Signal had not applied for permanent residency on their behalf and had no present intention to do so, Signal continued to deceive the workers into believing that Signal would apply for and help them obtain permanent residency
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status. Notably, in or about January 2007, Dewan and Burnett traveled to the man camp and, with Signal employee John Sanders present, told Plaintiffs and other Indian workers that Signal would provide each Indian worker, including Plaintiffs, with a green card. Later, in and about the first half of 2007, Signal posted notices in the man camp directing the workers to fill out certain legal forms and submit them, along with their passports, to Signal for green card processing.
157. Beginning before the January 2007 meeting and continuing throughout 2007, Signal employees communicated and consulted with each other and with the Agents concerning what to tell workers, including Plaintiffs, about the status of their visas and green card applications. Throughout that period, Signal and the Agents continued to assure Plaintiffs that they would receive green cards, both in private conversations and in meetings.
158. Signal also did nothing to address the fact that the Plaintiffs’ temporary employment at Signal (which Signal itself represented to the U.S. Department of Homeland Security, under penalty of perjury, would be completed “within the . . .year”) was not economically justifiable in light of the crushing amounts of debt Plaintiffs incurred and the mandatory $35 per day deduction for room and board.
159. By at least October 2006, shortly after the first workers (including Plaintiffs) arrived in Pascagoula, Signal personnel learned that each worker had been required to pay well over the equivalent of $10,000 to Pol, Burnett, and Dewan.
160. In internal correspondence and conversation, Signal personnel (including Signal executives) concluded that these “recruitment fees” were excessive and a root cause of dissatisfaction and low morale among the Indian workers.
161. Nevertheless, Signal did effectively nothing to remedy the situation.
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162. First, although Signal sent a letter to Dewan and Burnett requesting that they refund half of the fees that they had received, Signal did not terminate its relationship with Dewan or Burnett or impose any penalty or withhold any payment when those individuals refused to comply. In fact, Signal did nothing even after Burnett (i) asserted to Signal that Dewan had refunded the workers’ money, and (ii) furnished affidavits signed by workers attesting to the “fact” that they never paid any fees, both claims that Signal itself considered plainly false.
163. Second, despite believing that the fees being charged were unreasonable and were generating problems, Signal never demanded that Dewan or Burnett cease collecting such fees from new recruits who were still in India. Indeed, Signal continued to hire workers, including certain Plaintiffs, through Dewan and Burnett after it learned of the unreasonable fees that they charged, effectively ratifying the conduct of its Agents.
164. Third, Signal did not itself refund the unreasonable fees charged by the Agents, nor did Signal offer any assistance to mitigate the cost or modify its contract with the Agents in which it had been agreed that neither Signal nor Global would shoulder any of the “recruitment fees” for its Indian workers.
In an Attempt to Quell Rising Worker Dissatisfaction, Signal Sends Three Workers Back to India, One of Whom Attempts Suicide
165. By the spring of 2007 (approximately 3 to 4 months after workers first arrived), it became increasingly clear that the conditions at the Pascagoula camp were intolerable. Workers began to consider ways to convince Signal to improve the conditions and sought outside advice from local church goers and attorneys.
166. In late February 2007, when Signal learned that certain workers had contacted a lawyer, Signal threatened to send the most vocal workers back to India.
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167. To exert additional pressure over Plaintiffs, Dewan and Dewan Consultants intimidated the families of certain vocal workers. In or about March of 2007, a representative of Dewan Consultants called Plaintiff Aby Poulose’s family in India and warned them that Poulose would be sent back to India if he did not stop making trouble at Signal. Dewan called another vocal worker’s family and issued a similar threat. And around the same time, a Dewan Consultants employee called Plaintiff Ninan Tharakan’s family and warned them that they would have trouble in India if Tharakan created any problems in the United States.
168. News of these and other calls to India spread among the workers, and substantially heightened Plaintiffs’ fears that Defendants would retaliate, perhaps even with violence, against them and their families if they complained about or tried to leave the discriminatory and degrading conditions.
169. Signal escalated its pressure on the workers while continuing to mislead them about green cards. In a meeting with Plaintiffs and other workers on March 8, 2007, Signal management assured the workers that Signal would “take care” of their green cards. However, Signal management also told Plaintiffs that Signal would fight back against any “organizing” efforts, and that Signal would not extend any of the workers’ H-2B visas if a single worker took legal action against Signal.
170. On that same day, Signal decided to terminate and forcibly send back to India five of the ostensible “camp leaders,” and to do so in a way that would make an example out of them and intimidate the other workers into remaining scared and compliant.
171. Early in the morning of March 9, 2007—when the workers for both the day and night shifts were present at the camp—Signal locked the gate to the Pascagoula man camp, thereby blocking the only exit. At approximately the same time, Signal camp coordinator Darrell
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Snyder and five security guards swept through the bunkhouses carrying pictures of the men targeted for termination. Because Mr. Snyder and the security guards could not differentiate the appearance of these Indian men, they accosted numerous workers to determine whether they were the individuals shown in the pictures.
172. By 6:00 a.m., Signal had identified four of the five workers, taken them into “custody,” and told them that they were fired and would be deported. Distraught at what that meant for him and his family, one of these workers slashed his wrists and attempted suicide in front of Plaintiff Parshottam Mangani. The fifth worker fled the camp.
173. By early afternoon, local media, religious advocates, and other individuals had gathered outside the camp gates to express their concern over the attempted suicide and the forced detention of the other men.
174. The incidents of March 9, 2007 caused great fear in each of the Plaintiffs. Not only were they afraid of the worsening tension among the workers, they were scared of what Signal would do to them if they raised concerns about conditions at the camp. Plaintiffs believed, based on Signal’s conduct, that protesting their plight would lead to arrest, imprisonment, bodily harm, and deportation back to India.
175. Indeed, by its conduct over March 8 and 9, 2007, Signal intentionally created a climate of fear and intimidation in order to overawe the Plaintiffs and their coworkers into dropping their complaints about the camp and their treatment at the hands of Signal and its Agents.
Signal, Assisted by Burnett and Dewan, Used Fraudulent and Coercive Tactics to Keep Plaintiffs in the Pascagoula Camp
176. Following the March 9, 2007 incident, Signal and its Agents used additional fraudulent and coercive tactics to keep the workers, including Plaintiffs, under its control.
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177. In or about mid-March 2007, Burnett and Dewan traveled to the Pascagoula man camp to again reassure workers that they would receive green cards and warn them that they should not cause any trouble for Signal.
178. That same month, Signal Senior Vice President Ron Schnoor addressed the entire Pascagoula man camp about what had happened on March 9.
179. Schnoor used two tactics: fraudulent promises of long-term employment, and threats to send the workers back to India.
180. First, Schnoor assured the men that Signal would continue to employ them for the “long term.” That assurance was demonstrably false at the time, given that Signal still had not decided whether it would extend any of the workers beyond the initial ten-month visa period, and given that Signal had already begun to evaluate the Pascagoula workers and had decided to fire and not apply for visa extensions for certain workers.
181. Second, Schnoor threatened the men, telling them that if any one Indian worker filed a lawsuit against Signal, Signal would refuse to extend any of the H-2B visas for any of the workers, and would therefore send all of them back to India. Signal knew full well that this threat would coerce the workers, including Plaintiffs, into staying at the camp, lest they return to India in crushing debt.
182. Nevertheless, even given the threats and false promises, by March 2008, over three-quarters of the Indian workers in the Pascagoula camp had left Signal. Many were terminated; others left of their own accord—often by running away in the middle of the night— due to the low pay, abusive treatment, and deplorable living conditions.
183. No Plaintiff received a green card through the help of Signal or the Agents. Indeed, neither Signal nor the Agents ever applied for a green card for any Plaintiff.
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Malvern Burnett Purported to Act as Attorney to Plaintiffs, but In Reality Was Working Solely on Behalf of Defendants
184. At all relevant times, Burnett had an attorney-client relationship with each Plaintiff and, indeed, each Indian worker employed by Signal, for purposes of immigration issues and each Plaintiff’s work for Signal.
185. Burnett prepared the immigration forms required for Plaintiffs to apply for H-2B status. In completing those forms, Burnett represented to the U.S. Department of Homeland Security, under penalty of perjury, that the Plaintiffs would stay in the United States only temporarily, returning to India “within the coming year.” At the same time Burnett was submitting those forms, he was affirmatively telling the workers, including Plaintiffs, that they would be eligible for permanent residency, and that he would assist them in applying for green cards.
186. Further, Burnett learned that, after they arrived in the United States, the workers, including Plaintiffs, asked Signal personnel when they could expect to receive green cards. After learning this, Burnett did nothing to correct his clients’ misimpression.
187. To further his deception, Burnett concealed from Plaintiffs where his true loyalties lay. As noted above, by mid-2006 Burnett had entered into an attorney-client relationship with Signal for the broad purpose of applying for and obtaining lawful status for Indian workers to come to the United States. Later, in 2007, Signal and Burnett entered into a written Retainer Agreement memorializing the arrangement as it had been operating—namely that Burnett would “represent you [Signal] in the matter of H-2B Visa extensions for MS and TX” on immigration matters at zero cost while the fees for his work on behalf of Signal were to be taken from the Indian workers, including Plaintiffs.
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188. Burnett never disclosed his attorney-client relationship or payment arrangement with Signal to the Indian workers, including Plaintiffs, much less received their waiver of the conflict of interest it caused.
189. Burnett also entered into an attorney-client relationship with Dewan and Pol, starting no later than mid-2006. Burnett never disclosed this attorney-client relationship with Pol and Dewan to the Indian workers, including Plaintiffs, much less received their approval for it.
190. Burnett also had a “Multilateral Business Agreement” with Dewan and Pol, for the broad purpose of recruiting Indian workers to come to the United States. Burnett never disclosed this “Multilateral Business Agreement” to the Indian workers, including Plaintiffs, much less received their approval for it.
191. One incident in particular crystalizes the contempt with which Burnett viewed his Indian clients. On December 16, 2006, Burnett sent an email to Dewan and Pol regarding Pravin Kumar N. Patel, a Signal worker and client of Burnett. Patel had stopped payment on a check to Burnett. Burnett told Dewan and Pol to ensure that “the idiot” Patel restore the payment and threatened to have Patel’s visa “mysteriously” revoked if Patel did not pay. Later in the email, Burnett referred to all the Indian workers, who were his clients, as “the idiots” and speculated about whether he should threaten them with “immediate deportation” in order to prevent them from stopping payment on future checks.
192. Burnett also forwarded emails he received from his Indian worker clients to Dewan. Burnett forwarded these attorney-client protected communications without permission from his clients, the workers.
193. Such appalling behavior violates not only the Mississippi Rules of Professional Conduct for attorneys, but basic notions of loyalty, propriety, and honesty.
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Plaintiffs Each Relied on the Defendants’ Representations Lakshmanan Ponnayan Achari
194. In or about the last week of April 2006, Achari was working as a fitter in Chennai, India. A boy from Achari’s hometown in Southern India called Achari and said that he had seen newspaper advertisements offering the opportunity to live in the United States and obtain a green card. Achari subscribed to one of those newspapers, so he looked at the advertisement and confirmed that it promised the opportunity to get a green card.
195. Achari then spoke with a friend, who had been working with Dewan Consultants. The friend knew the personal phone number of a man named Salimon and called Salimon on behalf of Achari. Salimon said that Achari should come to an interview.
196. In or about May of 2006, Achari traveled with a friend to the friend’s interview with Dewan Consultants. Achari spoke directly with Salimon, who told Achari that there were job openings for fitters in the United States. Achari told Salimon that he did not have a passport, but Salimon assured him that this would not be a problem.
197. On Salimon’s recommendation, Achari took a written test for the fitter job. Salimon, Dewan, Pol, and, on information and belief, Signal employees were present for the test. Pol reviewed the test results and informed Achari that he passed. Dewan also reviewed the test results and made notations on Achari’s testing paperwork.
198. About two days later, Achari attended a group interview. At that interview, Salimon explained that Achari could obtain a green card. Salimon also told Achari that this process would cost 600,000 rupees (approximately $11,000).2

2

Unless otherwise specified, all U.S. dollar approximations are determined through the use

of a historical exchange rate calculator, available at

http://www.oanda.com/convert/fxhistory.

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199. Achari paid this amount to Salimon, Dewan, Burnett, and Pol in three installments in or about and between June and December of 2006. To raise this money, Achari sold his wife’s jewelry. He also incurred substantial debt: he obtained two loans, each at a 36 percent interest rate.
200. In or about November of 2006, Achari met with Dewan and, on information and belief, a Signal employee. Achari told Dewan that he had recently heard from other workers that they were receiving H-2B visas and that this was the first time Achari heard that he might receive anything besides a green card. Dewan assured Achari that Achari had paid for and would receive a green card.
201. Also in or about November 2006, Achari again met with Salimon. Salimon assured Achari that he would receive a green card within eight months.
202. In or about late November or early December 2006, just before he left for the United States, Achari quit his job at a workshop where he had worked for 25 years.
203. On or about December 4, 2006, the day he was scheduled to fly to the United States, Achari traveled to Dewan’s office in India to obtain his passport. Although Achari arrived in the morning, Dewan did not meet with him until the evening—just two hours before his flight was scheduled to depart. Dewan demanded that Achari sign blank pieces of paper and pay the final installment of his “recruitment fees” before Dewan would give him his passport. Achari felt intimidated and that he had no choice but to comply. He signed and left for the airport.
204. After arriving in the United States, Achari felt compelled to remain at Signal’s man camp because Signal would deduct living expenses from his paycheck even if he lived elsewhere. Moreover, he felt that he could not leave the job at Signal because he had taken out
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large loans at high interest rates to pay the “recruitment fees.” He knew he would not earn enough to pay those loans back and feed his family if he returned to India.
205. Defendants also continued to assure Achari that he would receive a green card. For instance, shortly after he arrived in Pascagoula, Achari attended a meeting led by Pol, Burnett, Dewan, and Snyder. At the meeting, Burnett said that Signal would apply for H-2B extensions for the workers three times, and would then apply for their green cards. In or about early-to-mid 2007, Achari attended another meeting led by Pol, Burnett, and Snyder. At that meeting, Burnett told the workers that he had applied for their H-2B extensions and that their green cards would also be processed.
206. Achari relied upon Defendants’ promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants’ “recruitment fees,” his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would take adverse immigration action against him, Achari felt intimidated into acquiescence and compelled to continue working for Signal.
Varghese Varkey Abraham 207. In or about May of 2006, Abraham was working as a welder in Dubai, when he saw a newspaper advertisement placed by Dewan Consultants. The advertisement offered the opportunity to obtain an H-2B visa and a green card with permanent residency in the United States. Abraham called Dewan Consultants and spoke to Salimon, who told Abraham to attend an interview in India. 208. Based on Salimon’s promises of a green card, Abraham quit his job in Dubai, purchased an airline ticket, and flew to India. 40

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209. On or about May 19, 2006, Abraham attended an interview with Michael Pol and Salimon. Pol and Salimon told Abraham he could obtain permanent residency and a green card if he worked in the United States. Pol and Salimon also asked Abraham to take a written test as part of his job application. After Abraham passed the test, Pol and Salimon gave Abraham a letter from Signal that promised permanent residency and a green card.
210. At the interview, Pol and Salimon told Abraham that the immigration process would cost about 600,000 rupees (approximately $13,187). Abraham paid this amount to Dewan, Salimon, Pol, and Burnett in installments. To raise the money, he used his savings, sold a small business that he had owned, and also took out a loan at a 10 percent monthly interest rate.
211. On or about November 26, 2006, Abraham traveled to Dewan Consultants’ office to pay Dewan the final installment of the “recruitment fees.” Dewan learned that Abraham did not have about 50,000 rupees (approximately $1,118) of the approximately 600,000 rupees that Defendants had demanded. As a result, Dewan refused to give Abraham his passport or his plane ticket to the United States. Dewan also opened Abraham’s suitcase and confiscated all of Abraham’s papers concerning permanent residency.
212. Over the next twenty-four hours, Abraham’s wife arranged for the remaining 50,000 rupees to be paid to Salimon. Only then did Dewan give Abraham his passport and plane ticket. He did not return Abraham’s documents concerning permanent residency. Abraham then flew to the United States.
213. Upon arriving at Signal, Abraham learned for the first time that Signal would deduct approximately $245 per week from his paycheck for food and housing and that he would be sleeping in a trailer with 23 other men. The food was terrible, and the work was much more dangerous than that to which he was accustomed. Nonetheless, he felt compelled to stay at the
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man camp and work for Signal because he had depleted all of his assets and incurred enormous debt to pay the “recruitment fees” that Defendants demanded. His H-2B visa only allowed him to remain in the United States if he worked at Signal, and he knew that if he returned to India, he would never be able to repay his loans.
214. Signal officials also continued to assure Abraham that they would process his green card. Throughout the first half of 2007, Abraham attended camp meetings approximately every two months at which Signal officials stated that they would extend the workers’ visas and obtain their green cards.
215. Abraham relied upon Defendants’ promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants’ “recruitment fees,” his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would take adverse immigration action against him, Abraham felt intimidated into acquiescence and compelled to continue working for Signal.
Kodakeril Baby Biji 216. In or about July 2006, Biji saw a newspaper advertisement offering the chance to obtain an H-2B visa and then permanent residency in the United States. In response, he called Dewan Consultants, and Salimon told Biji that he should attend an interview that would take place about one month later. 217. Salimon, Dewan, and two Signal employees were present at Biji’s initial interview. The Signal employees gave Biji a written test, and Salimon explained that Biji and the other attendees would obtain a ten month H-2B visa and then a green card. Salimon also
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explained that this process would cost over 600,000 rupees (approximately $12,500). This money would be paid to Dewan Consultants, Pol, and Burnett.
218. Relying on the Agents’ promises of receiving a green card, Biji quit his job of nine years and paid the 600,000 rupees demanded by the Agents between approximately July and December 2006. To raise the money, he used his savings and borrowed from a bank at an interest rate of approximately 10 to 13 percent annually. Biji borrowed other funds at a 20 percent annual interest rate.
219. Approximately one or two months after his initial interview, Biji brought a fee installment to Dewan and Burnett at a hotel in India. Burnett told Biji that he would receive a visa and gave Biji paperwork promising an H-2B visa and permanent residency. Then, on or about November 7, 2006, Biji met again with Salimon, who stated that Biji would travel to the United States for ten months on an H-2B visa, return to India, and then come back to the United States with a green card.
220. Just before Biji left India, Dewan forced him to sign paperwork written in English. Because Biji did not speak or read English, he could not understand what the paperwork said.
221. After arriving in the United States, Biji learned that the living conditions at Signal were terrible and that Signal staff members treated the Indian workers like animals. After a few months, Biji and three friends rented a local apartment for approximately $740 per month. Nonetheless, Signal continued to deduct $35 per day from Biji’s paycheck for room and board. Even though he was earning far less than he had been led to believe he would, Biji felt that he had no choice but to continue working for Signal because he had spent all of his savings and
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borrowed a great deal of money to travel to Mississippi. He believed that the only way he could earn enough money to repay his loans was to if he continue to work for Signal.
222. Biji also continued to believe that Signal would provide him with a green card. In or about December 2006, Biji met with Burnett and Sanders at the Pascagoula camp. Biji asked both Burnett and Sanders when he would receive his green card. Both assured him that Signal would file for his green card. In or about mid-2007, Biji also attended a meeting at which a Signal official again promised that the company would apply for the workers’ green cards.
223. Biji relied upon Defendants’ promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants’ “recruitment fees,” his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would take adverse immigration action against him, Biji felt intimidated into acquiescence and compelled to continue working for Signal.
Subhashithan Bahuleyan 224. In or about the spring of 2006, Bahuleyan saw a newspaper advertisement that Dewan Consultants had listed, offering an opportunity to work for a “Leading Marine and Fabrication Company” in Mississippi or Texas and obtain a “permanent-employment visa.” The advertisement listed interview and testing dates in July 2006. Bahuleyan attended one of these meetings, where he took and passed a written test administered by Dewan and a Signal employee. 225. After the test, Dewan and Salimon told Bahuleyan that if he accepted the job at Signal, he would travel to the United States on a nine-month visa and Signal would obtain a green card for him. Dewan and Salimon assured Bahuleyan that he would become a permanent 44

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resident of the United States and would be able to bring his family to live with him. Dewan told Bahuleyan that this process would cost 600,000 rupees (approximately $13,200).
226. Bahuleyan paid these “recruitment fees” to Dewan, Pol, and Burnett in installments between August and November 2006. To obtain the funds, Bahuleyan took out a loan with a monthly interest rate of approximately 7 percent. Due to the exorbitant interest rate, Bahuleyan ultimately paid over 1,800,000 rupees (approximately $39,600) to settle this debt.
227. In or about early November 2006, Bahuleyan met with Dewan, Salimon, and Burnett to discuss his upcoming interview at the U.S. consulate. They instructed Bahuleyan to tell the consular officials that he was only planning to stay in the United States for nine months.
228. Shortly after the interview, a Dewan Consultants employee called Bahuleyan and told him to bring his final installment to Dewan’s Mumbai office. On or about November 27, 2006, Bahuleyan traveled to Dewan’s office. As he waited in line to meet with Dewan, he saw a Dewan Consultants employee tell another man that he had not brought enough money. When the man told Dewan that he had no more money, Dewan told him that he could not go to the United States; the man began to cry.
229. Bahuleyan began to worry whether Dewan also would accuse him of not having enough money. Indeed, when Bahuleyan gave his money to Dewan and Dewan’s brother, they claimed that Bahuleyan owed an additional 33,000 rupees (approximately $700). Bahuleyan protested that he had brought the requested amount, but Dewan and his brother said that it was not enough. Dewan did not give Bahuleyan his passport until Bahuleyan called his wife and arranged for the remainder to be paid to a friend of Salimon. Shortly thereafter, Bahuleyan left for the airport and flew to the United States.
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230. When Bahuleyan arrived in the United States, he learned that Signal would deduct $705 from his paycheck for tools and $35 each day for room and board. Bahuleyan felt like a prisoner at the camp. Signal regulated every aspect of his life, including where he went, what he ate and drank, and what he could bring into the camp. Eventually, Signal reduced his salary to $12 per hour without explanation. Bahuleyan spoke with the general foreman, who told Bahuleyan that, if he was unhappy with this pay, he could return to India. Bahuleyan knew that he could not risk losing all of his income from Signal because the interest on his loans was increasing daily. He felt that he had no choice but to agree to this wage deduction.
231. In or about early 2007, Bahuleyan attended many meetings at Signal. Each time, Signal employees told the workers that the company would extend their visas and apply for their green cards. In particular, on or about March 7, 2007, Bahuleyan attended a meeting led by Signal’s Vice President. A number of workers asked about the status of their green cards, and the Vice President assured Bahuleyan and other workers that Signal would “take care of everything.”
232. On the day that Signal fired several Indian workers in March 2007, Bahuleyan traveled to the hospital with the Indian worker who attempted suicide. Bahuleyan explained to a doctor that he and other Indian workers had paid up to $20,000 to travel to the United States and had been promised green cards. He explained the stress that they were all under from the constant threats of deportation. A Signal safety officer who had accompanied them to the hospital overhead the conversation and warned Bahuleyan not to say anything negative about the company.
233. A few days later, Bahuleyan attended another camp meeting at which Dewan warned the workers not to make any trouble for Signal.
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234. Bahuleyan relied upon Defendants’ promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants’ “recruitment fees,” his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would take adverse immigration action against him, Bahuleyan felt intimidated into acquiescence and compelled to continue working for Signal.
Xavier Disoliyan 235. In or about June 2006, Disoliyan was working as a welder in Abu Dhabi and saw an advertisement in a local newspaper promising an opportunity to work for a “leading” United States marine company that would provide work visas and permanent residency. In or about July 2006, Disoliyan attended a walk-in skills test in India, at which Dewan, Salimon, and Signal representatives were present. At the skills test, Dewan and Salimon told Disoliyan and other workers that they would travel to the United States on H-2B visas. Dewan and Salimon also said that, after six months, the workers would receive green cards and would be able to bring their families to the United States. 236. Dewan and his agents told Disoliyan and others that they would need to pay over 700,000 rupees (approximately $14,436) for this opportunity. Disoliyan spoke privately with Dewan and Salimon and told them that he did not have enough money. Dewan and Salimon explained that Disoliyan could pay in installments, and he should take advantage of the opportunity because the job in the United Sates would allow him to save 150,000 rupees (approximately $3,000) every month. Based on Dewan’s and Salimon’s assurances, Disoliyan believed that he would be able to pay back any loans in as few as six months.
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237. Disoliyan paid the fees demanded by Dewan, Pol, and Burnett by using family property as collateral for loans. He secured a loan for approximately 300,000 rupees by posting the house that he had built and the property he had received as part of his wife’s dowry as collateral. Disoliyan borrowed the remaining 400,000 rupees (approximately $8,200) through a loan against which his brother-in-law offered his own house as collateral. Pursuant to the terms of this loan, Disoliyan was required to begin repaying the principal within one month, and a default would mean foreclosure on his brother-in-law’s home.
238. In or about August 2006, Disoliyan met with Dewan, Salimon, and Burnett to pay for what Burnett said was his permanent residency visa. At this meeting, Burnett assured Disoliyan that his permanent residency application would be granted.
239. In or about November 2006, Disoliyan traveled to Dewan’s office in Mumbai to pay his final fee installment and receive his plane ticket and passport. It was there that he first learned that Signal would charge him $35 per day for food and accommodations. Disoliyan was upset about this additional cost and concerned that it would make it more difficult for him to repay his loans. Dewan assured Disoliyan he would be able to send 150,000 rupees (approximately $3000) back to India each month. Regardless, Disoliyan decided that he had no choice but to agree because Dewan and his associates told him that if he refused, he would not receive a refund of the fees that he had already paid. Dewan also pressured Disoliyan to sign additional paperwork without giving him an opportunity to read it because they were in a rush to get to the airport.
240. Upon arrival in the United States, Disoliyan felt that Signal’s work conditions were unsafe. He did not express those concerns to Signal management, however, because he observed that Signal demoted, fired, suspended, or reduced the pay of Indian workers who
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complained about the conditions. At times, Disoliyan was unable to send enough money home to repay his loans because of the charges Signal deducted from his paycheck. Nonetheless, he was afraid to leave Signal because he had paid so much money to get there. He knew that he would never be able to earn enough in India to repay his debts.
241. Disoliyan relied upon Defendants’ promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants’ “recruitment fees,” his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would take adverse immigration action against him, Disoliyan felt intimidated into acquiescence and compelled to continue working for Signal.
Rajankunju Geevarghese 242. In or about April 2006, Geevarghese saw an advertisement in an Indian newspaper that offered jobs in the United States for pipefitters and welders. The advertisement also stated that workers would receive work visas and green cards. Geevarghese called Dewan Consultants and was told to attend one of a series of meetings scheduled for early May. 243. On or about May 2 or 3, 2006, Geevarghese attended a meeting at the Trident Hotel in Cochin, at which Dewan, Pol, and Salimon were present. Upon information and belief, Signal staff members were also present. During the meeting, Dewan said that the workers would initially receive H-2B visas, which would be extended for nine additional months. At the same time that the workers were processed for H-2B visas, Signal would also apply for green cards for every worker. Dewan stated that the cost for the entire process would be 700,000 rupees (approximately $15,630), which would be paid in three installments to Pol, Burnett, and Dewan. Either Dewan or Pol also promised that the workers would have good accommodations, with 49

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only two people per room. At Dewan’s request, Geevarghese and other interested workers signed a “temporary contract,” which documented what was discussed at the meeting, including the fees and the promise of a visa and a green card.
244. Approximately three days later, Geevarghese received a call from Salimon, who told him to attend a welding test on or about May 8, 2006. Geevarghese took two tests administered by two Signal employees. Salimon then informed him that he had passed and should begin to collect the money needed for his fees.
245. Although Dewan had initially told Geevarghese that the process would cost 700,000 rupees, the Agents ended up demanding even more from Geevarghese, which Geevarghese paid. In order to raise the money necessary to pay the fees, Geevarghese depleted his savings and sold his wife’s and his children’s jewelry. In addition, he took out one loan for 250,000 rupees (approximately $5,582) and another loan for 450,000 rupees (approximately $10,102), both at 24 percent annual interest rates.
246. Following his skills tests, Salimon called Geevarghese regularly to provide him with updates concerning the status of his case and to inform him when and where to pay the fee installments. Geevarghese paid these fee installments to Dewan, Pol, and Burnett in or about May through November 2006.
247. On or about November 6, Geevarghese met with Dewan, Salimon, and Sanders, who told him not to mention the fees he had paid to Dewan, Pol, and Burnett during his interview at the United States Consulate.
248. On or about November 24, 2006, Salimon arranged for Geevarghese to fly from Cochin to Mumbai so that he could make his final payment and receive his passport and plane ticket to the United States. When Geevarghese met with Dewan that day, Dewan insisted that
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Geevarghese pay an additional 4,000 rupees (approximately $90) for the plane ticket to Mumbai. Geevarghese had not been told about this fee and only had 6,000 rupees left for travel expenses. Dewan, however, refused to give Geevarghese his passport and ticket to the United States until he paid the 4,000 rupees. Intimidated by Dewan, afraid of being stranded in Mumbai, and fearful of losing the opportunity to work in the United States, Geevarghese paid Dewan. Dewan then demanded that Geevarghese sign several contracts without offering him enough time to review them.
249. In the United States, Geevarghese was shocked by the living conditions he was forced to endure. He also learned for the first time that Signal would deduct money from his paycheck for the tools he used. Nonetheless, Geevarghese was afraid to leave his position at Signal and return to India; he had sold everything of value that his family owned and knew he would never be able to pay back his enormous debts working in India.
250. Moreover, Signal officials and the Agents repeatedly reassured him and the other workers that Signal would process their green cards. In particular, Geevarghese attended a meeting in or about November or December 2006 at which John Sanders and a Signal Vice President stated that Signal would process the paperwork necessary to make the workers permanent residents. In or about March 2007, Geevarghese attended another meeting led by Signal senior management, Dewan, and Burnett. They again promised that Signal would process the workers’ green cards.
251. Geevarghese relied upon Defendants’ promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants’
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“recruitment fees,” his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would take adverse immigration action against him, Geevarghese felt intimidated into acquiescence and compelled to continue working for Signal.
Jomon George 252. In or about April or May 2006, J. George saw an advertisement in an Indian newspaper for pipefitting jobs in the United States. The advertisement stated that permanent residency status would be available to workers after six to nine months. J. George called the listed number and spoke with Salimon, who told him about an interview and informational seminar. Salimon and Dewan were present at the seminar, as were two or three men from Signal. Salimon explained that in order to obtain their green cards, the workers would need to pay Dewan, Pol, and Burnett 600,000 rupees (approximately $13,400). 253. J. George later took and passed a qualifying test. After the test, a Signal representative assured J. George that he would receive permanent residency status if he accepted the job with Signal. J. George then signed an agreement with Signal, which he understood to promise him a 10-month H-2B visa that would be extended and then converted into a green card. 254. In or about August 2006, J. George met with Burnett and Dewan, who promised him that the workers would receive green cards that would enable them to live and work permanently in the United States. 255. J. George paid the 600,000 rupees demanded by Dewan, Pol, and Burnett in installments in or about August through November 2006. In order to raise this money, J. George took out a loan at 18 percent annual interest, using a piece of land that his wife owned as collateral. He also sold all of his wife’s jewelry and borrowed money from his brother and several friends.
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256. Before flying to the United States, J. George traveled to Dewan’s Mumbai office to collect his passport and plane ticket and pay his final installment. J. George asked Dewan if he could get his money back if he did not want to go to the United States, but Dewan told him “no.” J. George felt he had no choice but to continue on to the United States. Dewan’s agents required J. George to sign various documents, but because the documents were in English and the agents rushed him, J. George did not have an opportunity to read or understand what he was signing.
257. In the United States, J. George and the other Indian workers were told by Sanders and other Signal officials that they would receive green cards, but that if they caused any trouble, they would be sent back to India. In early-to-mid 2007, J. George also saw a notice in the man camp advising workers to give their legal documents to Darrell Snyder for green card processing. Believing that Signal would finally begin to process his green card, J. George followed the directions.
258. J. George believed that he had no choice but to endure the unsanitary and unsafe conditions without complaint because Signal controlled his immigration status. He did not want to jeopardize his employment with Signal because he needed to earn enough money to pay off the debt he had incurred in order to pay Dewan, Pol, and Burnett.
259. J. George relied upon Defendants’ promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants’ “recruitment fees,” his fear that Signal would confiscate even more of his hard-earned wages,
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and his fear that Signal or Burnett would take adverse immigration action against him, J. George felt intimidated into acquiescence and compelled to continue working for Signal.
Shaiju Vadakkal George 260. In or about April 2006, S. George had been working as a welder in Oman for nine years when he learned from a friend about an advertisement for welding jobs and permanent residency in the United States. After calling Dewan Consultants and speaking with Salimon, S. George took emergency leave from his job to attend a seminar in India led by Dewan, Salimon, and Burnett. At the seminar, Burnett explained that the workers would travel to the United States on H-2B visas, which would be extended twice. They would then receive green cards and be able to bring their families to the United States permanently. Dewan explained that green card processing would cost 550,000 rupees (approximately $12,280), and H-2B processing would cost 200,000 rupees (approximately $4,460). 261. Approximately one month later, S. George received a call from Salimon, who explained that the fee had been reduced to 600,000 rupees (approximately $13,070). S. George said that he wanted to wait for a green card rather than start with an H-2B visa, but Salimon convinced him to start work on just an H-2B visa. Shortly after this conversation, S. George completed a skills test administered by Salimon and several Signal employees. After a Signal employee told George that he passed the test, Salimon instructed S. George to begin collecting money for his first payment. 262. S. George paid the 600,000 rupees demanded by the Agents by borrowing money at an interest rate of approximately 5 percent per month. He secured a second loan using his wife’s jewelry as collateral. Just before his consular interview, S. George resigned from his job in Oman.
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263. On or about November 28, 2006, S. George traveled to Dewan’s office to pay his final fee installment and receive his ticket and passport. Dewan refused to give S. George his ticket and passport, however, because Dewan claimed that he owed an additional 10,000 rupees. S. George knew that if he failed to pay the 10,000 rupees, he would forfeit all of the money that he had already paid to Dewan, Pol, and Burnett. S. George also felt compelled to pay because he had already quit his job in Oman and he could not make enough money in India to repay his debts. He begged some friends who were also at Dewan’s office to help him, and together, they were able to raise 10,000 rupees. After S. George paid his final fees, Dewan would not give him his ticket and passport until he had relinquished all of the receipts and documents that he had received in connection with his recruitment.
264. After S. George arrived in the United States, John Sanders told him that Signal would process his green card application. In or about March 2007, S. George attended a meeting at which Burnett, Dewan, and Sanders warned the Indian workers not to criticize Signal if they wanted to obtain green cards. Sanders stated very clearly that if the workers worked hard and behaved well, Signal would process their green cards.
265. S. George was very upset by the living and working conditions at Signal, as well as the sizable deductions that Signal took from his paycheck for accommodations and tools. However, S. George felt that he could not leave because he needed to earn enough money to repay the loans he had incurred in order to get to the United States. Moreover, after the March 2007 incident in which Signal fired a number of workers, S. George was terrified that if he caused any problems, Signal would fire him and have him deported.
266. S. George relied upon Defendants’ promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work
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for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants’ “recruitment fees,” his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would take adverse immigration action against him, S. George felt intimidated into acquiescence and compelled to continue working for Signal.
Praveen Kulathum Muriyil Gopalakrishnan 267. In or about June of 2006, Gopalakrishnan was working as a welder in Bahrain when he learned about a newspaper advertisement offering the opportunity to work for Signal in the United States and to obtain a green card. Because of this advertisement, Gopalakrishnan quit his job and traveled to India so he could apply to work at Signal. 268. On or about June 20, 2006, Gopalakrishnan traveled to a welding center in India to take a welding test for the Signal job. Salimon, Dewan, and a Signal employee were present. Salimon and Dewan spoke to the applicants. They said that applicants who were chosen for the job would work for Signal and obtain a green card. This process would cost 600,000 rupees (approximately $13,100). 269. Gopalakrishnan completed and passed the welding test. After the test, he was told to complete and sign several documents. He did not understand the documents, but he believed that they were part of the application process and would help him obtain a green card. 270. Gopalakrishnan ultimately paid the “recruitment fees” demanded by Dewan, Pol, and Burnett between approximately June and November 2006. To obtain this money, Gopalakrishnan mortgaged his home to a private lender at an interest rate of approximately 15 to 16 percent.
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271. Approximately two to three weeks after he took the welding test, Gopalakrishnan met with Salimon to discuss the job at Signal. Gopalakrishnan asked Salimon whether he would receive a green card, and Salimon assured him that Signal would help him obtain a green card.
272. On or about August 23, 2006, Gopalakrishnan met with Salimon and Burnett to pay an installment of his “recruitment fees.” At that meeting, Burnett promised Gopalakrishnan that he would receive a green card through his employment at Signal.
273. On or about November 18, 2006, Gopalakrishnan traveled to Dewan’s office in Mumbai to make his final payment and obtain his plane ticket to the United States. Dewan did not give Gopalakrishnan his passport until Gopalakrishnan gave Dewan his final fee installment.
274. Upon Gopalakrishnan’s arrival at the man camp, Signal employees informed him that he had to pay Signal $245 each week for room and board. Gopalakrishnan asked if he could rent an apartment outside the man camp, but Signal employees told him that he had to remain at the man camp. Gopalakrishnan felt like a prisoner at Signal. He was monitored constantly, and his foreman repeatedly threatened to report him for poor workmanship. Gopalakrishnan felt that he could not complain about the living and working conditions because he needed the job to repay his debts. Moreover, he was afraid to leave the camp because he thought that Signal employees would find him and send him back to India.
275. In addition, Signal and the Agents continued to promise Gopalakrishnan that he would receive a green card. In particular, in or about February or March 2007, Gopalakrishnan attended a camp meeting led by Burnett and Dewan, who told Gopalakrishnan and other workers that Signal was in charge of their green card processing.
276. When Gopalakrishnan finally escaped from the man camp, he attempted to access his bank account and discovered that Signal had frozen his account.
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277. Gopalakrishnan relied upon Defendants’ promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants’ “recruitment fees,” his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would take adverse immigration action against him, Gopalakrishnan felt intimidated into acquiescence and compelled to continue working for Signal.
Mouleswararao Guntamukkala 278. On or about May 23, 2006, Guntamukkala read a newspaper advertisement placed by Dewan Consultants. The advertisement offered the opportunity to work in the United States and obtain a green card. That same day, Guntamukkala spoke with a representative of Dewan Consultants, who told him that he could obtain an H-2B visa, which would be converted to a green card if he worked at Signal for one year. 279. Approximately one week later, Guntamukkala attended a small meeting at the office of Dewan Consultants, where Dewan explained the process in similar terms. Dewan also stated that it would cost each worker the equivalent of approximately $20,000. Shortly after the meeting, Guntamukkala took and passed a welding test, at which Dewan, Pol, and a Signal employee were present. Dewan and Pol gave Guntamukkala a signed statement promising that he would receive a green card if he passed his welding test and worked at Signal. 280. In order to raise the money to pay Dewan, Pol, and Burnett, Guntamukkala borrowed the equivalent of approximately $7,000 from a neighbor at approximately 3 percent interest per month. He also borrowed approximately $12,000 from his closest friend at 2 percent interest per month and sold his home—the only property he owned—to repay his friend. Guntamukkala borrowed the remainder of the fees from his family. Guntamukkala paid all of 58

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the fee installments that the Agents demanded between June and November 2006. Dewan Consultants withheld his passport until he paid this money.
281. After arriving in the United States, Guntamukkala asked a Signal employee when he would obtain his green card. The employee told Guntamukkala that the green card paperwork was being processed slowly due to the large number of people who would be obtaining green cards. He told Guntamukkala not to worry, however, and assured him that he would receive a green card. In or about early-to-mid 2007, Guntamukkala also attended a camp meeting at which Signal employees informed the workers that Signal was processing their green cards.
282. Despite the dangerous and difficult work conditions at Signal, Guntamukkala was afraid to complain. When he told a supervisor that Signal was pushing him to work too hard, the supervisor told him that Signal would send him back to India if he complained again. Guntamukkala thought about leaving Signal every day, but he felt that he had no choice but to stay. He knew that he could not repay his debts if he returned to India. Moreover, Signal had all of his paperwork, and he could not work for any other employer in the United States under the terms of his H-2B visa.
283. Guntamukkala relied upon Defendants’ promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants’ “recruitment fees,” his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would take adverse immigration action against him, Guntamukkala felt intimidated into acquiescence and compelled to continue working for Signal.
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Eldose Isac 284. In or about May of 2006, Isac saw a newspaper advertisement in a local Indian paper offering the opportunity to work as a welder or pipe fitter in the United States, where he could obtain permanent residency. The advertisement listed Dewan Consultants’ contact information. Isac called the phone number listed and spoke with Salimon. Salimon told Isac to attend a skills test and interview, where Isac could learn more about this opportunity. 285. Instead of traveling to Dubai, where he had secured a job as a pipe fitter, Isac attended the test and interview. He met with Salimon and two or three Americans, who Salimon introduced as representatives of Signal. Isac took a written test, and a Signal official informed him that he had passed. 286. Isac then spoke with Salimon, who promised Isac that he would be able to leave for the United States within six months on an H-2B visa and would receive a green card in the United States. Salimon told Isac that this process would cost 650,000 rupees (approximately $13,500). He assured Isac that once he received his green card, he could bring his family to the United States as well. 287. Isac paid the 650,000 rupees to Burnett, Pol, and Dewan in installments between approximately August and November 2006. To obtain this money, Isac used his sister’s and mother’s gold jewelry and his family’s land as collateral to obtain loans from banks. Isac also obtained additional loans from friends. 288. On or about August 6, 2006, Isac paid his first installment to Burnett, Salimon, and Dewan. Burnett gave Isac a receipt documenting his payment for “employment based permanent residence visa processing for Signal International.” 289. Shortly after this meeting, Isac’s prospective employer in Dubai told Isac to travel to Dubai as soon as possible to beginning working. Isac told Salimon that he was considering 60

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this opportunity, but Salimon promised Isac that he would travel to the United States soon, and it would not be worthwhile for Isac to travel to Dubai to work for a short time. Isac declined the job opportunity in Dubai.
290. In or about September or October 2006, at two different meetings, Salimon and Dewan told Isac not to tell United States consular officials that he would receive a green card. They assured him that this was part of the process, and any other answer would prevent him from traveling to the United States. Isac felt compelled to follow Dewan and Salimon’s instructions because he had already given up his job in Dubai and had incurred substantial debt. In at least one of these meetings, Dewan assured Isac that he would receive permanent residency after arriving in the United States.
291. On or about November 23, 2006, Isac traveled to Dewan’s office in Mumbai to make his final payment. Dewan’s staff forced Isac to sign, quickly, documents written in English. They did not allow Isac to read the documents and told him that the documents only contained formalities. Only after Isac signed the documents and gave Dewan's staff all of the paperwork related to his recruitment did he receive his passport.
292. After Isac had arrived at Signal, he asked John Sanders when he would receive a green card. Sanders told Isac that his “paperwork would move forward” and would be ready for him. Isac understood this to mean that he would receive a green card.
293. Isac was very unhappy with the conditions at Signal. When he arrived in the United States, he learned that Signal would deduct $35 per day from his paycheck for room and board. Despite the fact that this deduction severely reduced Isac’s wages, he felt compelled to endure the conditions at Signal because he needed the job to repay his debts.
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294. Isac felt that he could not even complain about the conditions at Signal because Signal might deport him. Signal’s camp manager told Isac that his H-2B visa prevented him from working for another company and he would be deported if he looked for another job. Signal employees also posted a notice in the man camp warning employees about the dangers of losing their immigration status. After the March 2007 incident during which several workers were fired, Isac felt particularly afraid that he would be deported or fired if he tried to leave the man camp or asked for help from someone outside Signal.
295. In or about July 2007, Isac attended a meeting at which Signal employee Darrell Snyder told Isac that Signal was applying for the workers’ visa extensions and assured him that Signal would also apply for their green cards. When Signal posted a list of workers for whom they had submitted visa extension applications, Isac’s name was on the list. Isac believed that this meant he would also eventually receive a green card.
296. Isac relied upon Defendants’ promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants’ “recruitment fees,” his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would institute adverse immigration action against him, Isac felt intimidated into acquiescence and compelled to continue working for Signal.
Raveendranathan Mookaparambil Itty 297. In or about late 2005, Itty saw a newspaper advertisement in Abu Dhabi offering the opportunity to work in the United States. Itty called the phone number listed on the advertisement and spoke with Dewan. Dewan told Itty to attend an upcoming meeting at a hotel in Abu Dhabi. 62

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298. Approximately one month later, Itty attended the meeting. Only two other potential workers were present. Dewan gave a presentation and stated that the opportunity to work in the United States would cost 500,000 rupees (approximately $10,600). Itty was hesitant to pursue the opportunity because he thought the cost was too high.
299. In or about February 2006, a friend told Itty that he had given money to Dewan Consultants. Itty called Salimon, who told Itty to attend another upcoming meeting at a hotel. Dewan and two other people led that meeting. Dewan explained to the audience that they were looking for employees to work in the United States for Signal and obtain a visa and permanent residency. Dewan explained that the workers would receive green cards after arriving in the United States and could bring their families for an additional fee. He again said that this process would cost 500,000 rupees (approximately $10,600), which would include payments to Dewan, Pol, and Burnet. Dewan explained that Pol and Burnett worked with Signal.
300. Shortly after the meeting, Itty took a skills test administered by Signal employees. He was then interviewed by Signal’s piping superintendent. These Signal employees told Itty that he would obtain an H-2B visa within 6 months, and would receive a green card within 18 months to 2 years.
301. Itty paid all of the fees demanded by Dewan, Pol, and Burnett in or about July through December 2006. He raised the money for these fees by mortgaging his home and taking out a loan at an interest rate of approximately 13.5 percent.
302. The day that Itty was scheduled to fly to the United States, he met with Dewan at his office in Mumbai. Dewan refused to give Itty his passport until Itty paid the remaining balance of his fees and gave Dewan all of the documents relating to his recruitment. Then, just before Itty left for the airport, Dewan required Itty to sign several documents. Itty did not
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understand the documents, but he felt that he had no choice but to sign because he had already paid so much money to the Agents and knew that they would not refund these fees.
303. After Itty arrived at Signal, Signal deducted approximately $400 to $450 each week from his paycheck for room and board. Because this cost would be deducted even if he lived elsewhere, he felt compelled to remain at the man camp. He feared that if he complained, he would be fired or deported. He was also afraid that if he left Signal, Signal would call immigration officials or the police, and he would be arrested or deported. He knew that if he were sent back to India, he would not be able to repay his debts.
304. Itty also felt compelled to remain at Signal because Defendants continued to promise him a green card. For instance, in or about February 2007, Dewan came to Signal and explained to Itty and the other workers that their visas would be extended, and that they would eventually receive green cards.
305. Itty relied upon Defendants’ promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants’ “recruitment fees,” his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would institute adverse immigration action against him, Itty felt intimidated into acquiescence and compelled to continue working for Signal.
Joy Jacob 306. In or about mid-2006, Jacob saw a newspaper advertisement offering jobs in the United States. He called Dewan Consultants, and was invited to attend a meeting at which Dewan, Salimon, Pol, and Burnett were present. At the meeting, Dewan and Salimon showed a video about Signal and told the attendees that Signal would provide green cards for the workers 64

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after they had been at Signal for approximately nine months. At this meeting, Jacob also signed some documents that were written in English. Although he could read some English, he could not understand what the documents said.
307. During additional meetings with Dewan, Pol, and/or Burnett in India, the Agents made numerous representations that led Jacob to believe that in exchange for paying thousands of dollars in “recruitment fees,” Signal and the Agents would assist Jacob with applying for and receiving permanent residency in the United States.
308. In reliance on these promises, Jacob paid approximately 600,000 rupees (approximately $13,187) in “recruitment fees” to Dewan, Pol, and Burnett, and paid an additional 200,000 rupees (approximately $4,395) in travel expenses. In order to raise this money, Jacob took out private loans, using his house and his parents’ house as collateral.
309. Soon after arriving in the United States, Signal officials told Jacob that his visa would be extended and that he would receive a green card. However, Jacob was very unhappy with the squalid living conditions, the inedible food, and the dangerous working conditions. After Signal fired several workers in March 2007, Jacob became afraid to criticize Signal because he did not want to be deported. Jacob felt compelled to remain at the man camp and work for Signal because he needed to repay his debts and knew that he would not earn enough to do so in India.
310. Jacob relied upon Defendants’ promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants’ “recruitment fees,” his fear that Signal would confiscate even more of his hard-earned wages,
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and his fear that Signal or Burnett would institute adverse immigration action against him, Jacob felt intimidated into acquiescence and compelled to continue working for Signal.
Biju John 311. In or about April or May of 2006, John read an advertisement in an Indian newspaper for a job in the United States that would pay $144 per day and promised H-2B work visas or green cards. John called Dewan Consultants and spoke with a representative of the company. The representative told John that Malvern Burnett would obtain a green card for him and that the process would cost 650,000 rupees (approximately $14,515). 312. John attended a seminar in or about May 2006, where he met Dewan, Salimon, Pol, Burnett, and Sanders. They confirmed that John would need to pay 650,000 rupees in “recruitment fees.” They also told John that if he paid Burnett an additional $4,000, he could work anywhere in the United States. 313. John paid Dewan, Pol, and Burnett 650,000 rupees in three installments. John also paid an additional 400,000 rupees (approximately $8,350) in travel and other expenses related to this process, resulting in a total cost of 1,050,000 rupees (approximately $22,865). 314. John raised the money for these expenses and fees by selling a piece of property that he owned, borrowing money from his brother, and borrowing money that his father raised by selling land and other items. He also borrowed 150,000 rupees (approximately $3,130) at 5 percent monthly interest. 315. On or about November 19, 2006, John traveled to Dewan’s Mumbai office to collect his passport and plane ticket to the United States. Shortly before John left to catch his flight, Dewan gave him a “service agreement” document and told him to sign it immediately. Dewan told John that he could not board the plane until he signed the agreement. Dewan also said that if John missed his flight, he could not recover the money he had paid. Because his 66

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flight was about to leave, John quickly signed the agreement without reading it. When Dewan gave John his passport and plane ticket, John learned he had paid twice the value of the plane ticket.
316. After arriving in the United States, John felt compelled to live at Signal’s man camp because Signal would deduct living expenses from his paycheck even if he lived elsewhere. John was shocked at the terrible living conditions and dangerous working conditions, but he was afraid to complain because Signal threatened to send him and other workers back to India if they misbehaved or spoke to others about Signal’s actions. John also felt that he could not leave his job at Signal. He had sold all of his property and borrowed a large amount of money to come to Signal. He knew that he could not make enough to repay his debts and support his wife and children if he returned to India. John was even afraid to leave the camp, because he thought he would be arrested or deported.
317. In addition, Signal and its Agents continued to promise him a green card. In or about December 2006, John asked Sanders when he would receive a green card. Sanders replied that Signal would apply for an H-2B extension and would then apply for his green card. In or about late 2006 or early 2007, John also saw notices in the man camp advising workers to ensure that their names were spelled correctly on their immigration documents so that Signal could process their green cards.
318. John relied upon Defendants’ promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants’ “recruitment fees,” his fear that Signal would confiscate even more of his hard-earned wages, and his fear that
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Signal or Burnett would take adverse immigration action against him, John felt intimidated into acquiescence and compelled to continue working for Signal.
Shibu Joseph 319. In or about April 2006, S. Joseph read a newspaper advertisement offering the opportunity for pipe fitters to work in the United States and obtain green cards. He spoke with a representative of Dewan Consultants, who invited S. Joseph to attend a seminar in May to learn more about the opportunity. 320. On or about May 2, 2006, S. Joseph attended a seminar at which Pol, Burnett, Dewan, and Salimon were present. Either Pol or Burnett (S. Joseph is uncertain of which) explained that workers would travel to the United States on H-2B visas, which would be extended for 18 to 24 months while their green card applications were processed. After they received green cards, the workers would be able to bring their families to the United States. Dewan explained that this process would cost a total of 600,300 rupees (approximately $11,000) to be paid in installments to Burnett, Pol, and Dewan. S. Joseph called Salimon after the seminar, and Salimon confirmed that workers would receive H-2B visas and green cards. 321. In or about May 2006, S. Joseph took a written exam administered by a Signal official. Salimon and Dewan were also present, and Salimon again assured S. Joseph that those who were hired would travel to the United States on H-2B visas while their green cards were being processed. 322. To pay his “recruitment fees,” S. Joseph posted his wife’s jewelry as collateral for a loan, and borrowed additional money from his brother, a friend, and his wife’s family. S. Joseph also borrowed money from an acquaintance at approximately 3 percent interest per month. S. Joseph paid his first and second fee installments in or about August and November 2006, respectively. 68

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323. On the day of his flight to the United States, S. Joseph traveled to Dewan’s office in Mumbai and paid his final fee installment. At Dewan’s office, either Dewan’s assistant or his brother took all of S. Joseph’s receipts and paperwork relating to his recruitment. S. Joseph feared that if he refused to give up his paperwork, he would lose the money he had paid. Dewan then demanded that S. Joseph quickly sign a number of papers, and said that he would not give S. Joseph his passport if he refused. Afraid that he would lose all of the money he had already paid and the opportunity to work in the United States, S. Joseph signed the papers without having a chance to read what they said.
324. At Signal, S. Joseph asked permission to live outside the man camp, but Sanders told him that the costs for room and board would be deducted from his wages even if he did not live there. Because he could not repay his loans if he paid room and board both to Signal and outside the man camp, S. Joseph felt that he had no choice but to remain at the camp. The living and working conditions were deplorable, and the food often made him sick. However, he felt compelled to continue to work for Signal because it was the only way that he could repay his debts and keep his family from being cast into poverty. S. Joseph also attended meetings in or about early 2007 at which Signal officials promised that they would obtain green cards for the workers.
325. S. Joseph relied upon Defendants’ promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants’ “recruitment fees,” his fear that Signal would confiscate even more of his hard-earned wages,
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and his fear that Signal or Burnett would take adverse immigration action against him, S. Joseph felt intimidated into acquiescence and compelled to continue working for Signal.
Thansilas Joseph 326. In or about June of 2006, T. Joseph was working as a welder for a large company in India when he saw a newspaper advertisement offering the opportunity to work for Signal in the United States and to obtain a green card. The advertisement stated that those interested in the opportunity should attend a meeting and interview session. 327. Four or five people participated in T. Joseph’s interview, including Dewan, Salimon, and two Americans. Salimon assured T. Joseph that if he worked for Signal, the company would process a green card for him within 10 to 15 months. Salimon said that T. Joseph would be able to bring his family to the United States, his wife would be able to obtain a good job, and that his children would be able to attend good schools. Dewan and Salimon told T. Joseph that this process would cost 800,000 rupees (approximately $17,432). T. Joseph told Dewan and Salimon that this was too much money. 328. The following day, Joseph attended a second interview. He spoke again with Dewan and Salimon, who agreed that T. Joseph could pay 600,000 rupees (approximately $13,074) instead of 800,000 rupees. T. Joseph then took a welding test, which Dewan, Salimon, and the Americans supervised. One of the Americans told T. Joseph that he had passed the test. 329. Between approximately June and December 2006, T. Joseph paid at least 600,000 rupees in installments to Pol, Burnett, Dewan, and Salimon. To obtain the money that they demanded, T. Joseph sold some jewelry belonging to his wife and children and posted the remaining jewelry as collateral for a loan at a 2 percent monthly interest rate. In addition, he sold the land his wife had provided as dowry for their marriage. Finally, T. Joseph borrowed about 300,000 rupees (approximately $6,702) from a private lender at a 9 percent monthly 70

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interest rate, using his family home as collateral. T. Joseph sold these possessions and borrowed money at such high interest rates because Salimon and Dewan had assured him that he would be able to receive a green card, bring his family to the United States, and obtain a good job at Signal.
330. In or about early November of 2006, T. Joseph traveled to a hotel before his interview with the U.S. consulate. At the hotel, T. Joseph met with Dewan, Salimon, and some American men, including Malvern Burnett. Beginning soon after this meeting, Salimon and Dewan repeatedly called T. Joseph and pressured him to pay the remainder of his “recruitment fees.”
331. On or about December 5, 2006, T. Joseph traveled to Dewan’s office to pay his final fee installment and obtain his passport. T. Joseph saw Dewan threaten other workers and warn them that they could not take receipts detailing their payments to Defendants to the United States.
332. When it was T. Joseph’s turn to meet with Dewan, Dewan demanded that T. Joseph sign papers written in English. T. Joseph could not read English, so he asked Dewan what the paperwork said. Dewan refused to answer and demanded that that T. Joseph sign quickly. T. Joseph was intimidated and feared that if he did not pay Dewan or sign the documents, he would lose the money that he had incurred substantial debt to pay to the Agents. T. Joseph therefore signed the documents and paid his final payment to Dewan. Only then did Dewan give T. Joseph his passport.
333. Upon arrival in the United States, Signal employees required T. Joseph to sign several forms written in English. T. Joseph could not read the forms, but he felt compelled to sign them so that he could begin working and repaying his debt.
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334. Approximately every two weeks between December 2006 and November of 2007, T. Joseph attended several camp meetings with Signal officials. At these meetings, Signal officials repeatedly assured the workers that their visas would be extended and that they would receive green cards. Dewan also spoke at a meeting in or about March of 2007. At this meeting, Dewan told T. Joseph and other workers that if they continued to work hard and listen to Signal’s instructions, they would receive green cards.
335. After T. Joseph received his first paycheck, he learned that Signal was deducting approximately $240 per week for room and board. When T. Joseph asked a Signal manager if he could live outside the man camp, the manager warned T. Joseph that he could not work for Signal if he lived outside the man camp, and would likely be deported. T. Joseph felt that he had no choice but to stay at the man camp. T. Joseph also felt that his only option was to continue to work for Signal for as long as he could. He had incurred so much debt to come to the United States that he felt that he would rather die than face the shame of returning to India, where he would not able to repay his loans and support his family.
336. T. Joseph relied upon Defendants’ promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants’ “recruitment fees,” his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would take adverse immigration action against him, T. Joseph felt intimidated into acquiescence and compelled to continue working for Signal.
Kulath Somanathan Kalayam 337. In or about April 2006, Kalayam saw an advertisement in the Malayalam Manorama newspaper offering United States H-2B visas and “employment based green card[s].” 72

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Kalayam called the number listed in the advertisement and spoke with Salimon, who invited him to a meeting in Cochin that would take place later that week. At the meeting, Salimon explained that workers would travel to work at Signal on H-2B visas and that Signal would provide them with green cards in approximately eighteen months. Salimon also explained that applicants would have to pay 600,000 rupees (approximately $14,100) in three installments to Dewan, Pol, and Burnett. Dewan, Pol, and Burnett were also present at the meeting.
338. Kalayam paid the 600,000 rupees to Dewan, Pol, and Burnett between approximately June and November 2006. In order the raise the money to pay these fees, Kalayam depleted his life savings, including money that he had saved to buy a house for his family.
339. Kalayam also met with Burnett, Dewan, and Salimon several times between approximately June and November 2006. In or about August 2006, Kalayam signed agreements with Dewan, Burnett, Global, and Signal. The agreement with Dewan stated that Dewan would proceed with his “employment based permanent residence visa.” Shortly thereafter, Kalayam met with Burnett, Salimon, and Dewan.to make a fee payment. He spoke with Dewan and Salimon, who assured him that they would process his green card. He also received a receipt from Burnett memorializing his payment of $1,427.50 for “employment based permanent residence visa processing for Signal International.” Although Kalayam asked Salimon for a receipt for the money he had paid to Dewan, Salimon said he could only give Kalayam a receipt if he paid additional fees.
340. In or about September or October 2006, Kalayam was informed that the medical test he had taken was invalid and he needed to take another one. He had to pay approximately 2,000 additional rupees (approximately $470) for this test.
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341. Soon thereafter, Kalayam met with Burnett, Dewan, and Salimon to discuss his upcoming interview at the U.S. consulate. Salimon told Kalayam not to disclose the fees he had paid. He also instructed Kalayam and to tell consular officials that he planned to return to India before the end of July 2007.
342. In or about November 2006, Kalayam traveled to Dewan’s Mumbai office to make his final fee payment and collect his passport. Before Dewan gave Kalayam his passport, he demanded that Kalayam return all of the paperwork relating to the Signal opportunity. Kalayam told Dewan that he did not have his paperwork, and Dewan threatened to withhold his passport. Kalayam was afraid that he would lose all of the money he had already paid to Dewan. He had seen Dewan forcibly take documents from several workers that day and refuse to give travel documents to other workers who failed to pay the amount demanded by Dewan. Ultimately, Dewan relented, but he insisted that Kalayam sign a number of documents quickly, without reading them. Only after Kalayam had signed the documents did Dewan give him his passport.
343. After arriving at Signal in or about December 2006, Kalayam was horrified to discover that he had to live in a crowded trailer and that Signal would deduct $35 per day from his paycheck for food and accommodations. Nonetheless, Kalayam felt that he had no choice but to remain at Signal. He had used all of his family’s savings to travel to the United States to get his green card, and he knew that all of that money would be lost if he went back to India. Kalayam was afraid to criticize Signal because Signal officials threatened to deport the workers if they caused any trouble. He was even afraid to leave the camp because he thought that the police or immigration workers would arrest him.
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344. In addition, Signal officials and the Agents continued to promise Kalayam that he would a receive green card. In or about early 2007, Kalayam attended a meeting at which Dewan, Burnett, and Sanders promised the workers that Signal would apply for their green cards. In or about March 2008, John Sanders called a meeting and reiterated that Signal would process the workers’ green cards.
345. Kalayam relied upon Defendants’ promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants’ “recruitment fees,” his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would institute adverse immigration action against him, Kalayam felt intimidated into acquiescence and compelled to continue working for Signal.
Sunilkumar Marottikkal Kuttan 346. In or about May or June of 2006, Kuttan read a newspaper advertisement offering the opportunity to work in the United States and obtain an H-2B visa and green card. The advertisement listed the contact information for Dewan Consultants. A few days after seeing the advertisement, Kuttan attended a large meeting, where Salimon, Dewan, Burnett, and Sanders were present. Dewan and Salimon explained that Kuttan and other Indian workers would travel to the United States and work at Signal for eleven months while their green cards were processed. Afterwards, they would return to India for a very short time after which they could come back to the United States with their families. 347. In or about May or June of 2006, Kuttan met with Sanders and another American to take a welding test.
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348. Kuttan ultimately paid Dewan, Pol, and Burnett approximately 600,000 rupees (approximately $13,170) in installments between June and December 2006. To pay these fees, Kuttan sold his wife’s wedding jewelry, borrowed money from his family, and took out a loan at 18 percent interest.
349. In or about December of 2006, Kuttan traveled to Dewan’s office to collect his plane ticket and passport. Dewan required Kuttan to sign some documents before receiving his ticket and passport. Because Dewan rushed him, Kuttan did not have time to read the documents or understand what he had signed.
350. After Kuttan arrived at Signal, Signal and the Agents continued to promise that he would receive his green card. In or about July 2007, he attended a meeting at which Signal officials stated that they would provide the workers with visa extensions and green cards. Kuttan later made an appointment with Burnett to ask him when he would receive his green card. Burnett also told Kuttan that Signal would apply for his green card.
351. Kuttan relied upon Defendants’ promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants’ “recruitment fees,” his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would take adverse immigration action against him, Kuttan felt intimidated into acquiescence and compelled to continue working for Signal.
Bhaskaran Sreedharan Kutty 352. In or around May of 2006, Kutty saw an advertisement in an Indian newspaper that offered the opportunity to work in the United States and obtain permanent residency. The advertisement instructed interested applicants to attend a meeting at a hotel in Cochin. Kutty had 76

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recently completed interviews with a Singapore company and made arrangements to begin working there, but he felt that he could not ignore an opportunity to live and work in the United States.
353. Kutty attended the meeting in Cochin, which was led by Burnett, Dewan, and a Dewan Consultants employee. They told Kutty that they would provide workers with a job at Signal in the United States, a green card, and living accommodations. The recruitment process would cost 700,000 rupees (approximately $15,564). Soon after this meeting, Kutty took a written and practical test.
354. In or about June 2006, Kutty was informed that he had passed the tests. He decided to pursue the Signal opportunity and pass up the job in Singapore.
355. Kutty paid Dewan, Pol, and Burnett the 700,000 rupees in “recruitment fees” in installments between approximately June and December 2007. To raise the money, Kutty obtained a loan at a 13 percent interest rate by using gold and property as collateral.
356. In or about June or July 2006, Kutty visited Dewan’s office and asked whether he would receive a green card if he worked for Signal. One of Dewan’s employees assured him that he would. On the basis of this promise, Kutty made his first fee payment.
357. On or about August 9, 2006, Kutty met with Dewan, Burnett, and another American to prepare for Kutty’s interview with the U.S. Consulate. They instructed Kutty not to tell the consulate that he would receive a green card.
358. On or about December 17, 2006, Kutty traveled to Dewan’s Mumbai office to make his final fee payment. Only after Kutty paid Dewan in cash did Dewan give Kutty his passport and airline ticket. Kutty was also required to sign several documents written in English,
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which he did not understand. Because the Dewan Consultants employees had left him very little time to get to the airport, Kutty quickly signed the documents so he would not miss his flight.
359. In the United States, Signal deducted approximately $400 from Kutty’s paycheck for tools. Signal also deducted between $200 and $300 per week for food and housing.
360. Kutty felt compelled to endure the deplorable conditions at Signal. He saw Signal employees retaliate and threaten to deport Indian workers who complained. Kutty feared that if he complained, Signal would also retaliate against him or have him deported. He knew that he could not afford to be sent back to India, where he would not be able to repay the debts he had incurred to pay Defendants’ “recruitment fees.”
361. Kutty relied upon Defendants’ promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants’ “recruitment fees,” his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would take adverse immigration action against him, Kutty felt intimidated into acquiescence and compelled to continue working for Signal.
Parshottam Ramchandra Mangani 362. In or about and between April and July 2006, Mangani read a newspaper advertisement for a job that offered permanent residency in the United States. 363. In or about the summer of 2006, Mangani attended a seminar in New Delhi, where Dewan and an American gave a presentation about a job opportunity. They explained that Mangani and other workers would travel to the United States on H-2B visas, which would then be converted into green cards. Dewan then distributed documents which stated that the process would cost 700,000 rupees (approximately $15,155). 78

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364. Mangani paid Dewan, Burnett, and Pol these “recruitment fees” in installments in or about and between July and November of 2006. To raise the money to pay these fees, Mangani sold a 2 acre farm that had provided much of his family’s income. He also sold a residential property he owned with a relative. After these sales, the only property his family owned was his father’s house, where Mangani and his mother, wife, and daughter also lived.
365. Just before he flew to the United States, Mangani traveled to the office of Dewan’s agent. An employee demanded that Mangani sign paperwork. Mangani asked if he could read the paperwork, but the employee insisted that Mangani’s flight to the United States would leave soon, and there was no time to read the paperwork. Mangani felt that he had no choice but to sign. Only then did Mangani receive his passport.
366. After Mangani arrived in the United States, Signal required him to sign paperwork agreeing that Signal could deduct $245 per week from his paycheck for food and housing. When Mangani and other workers asked if they could live outside of the man camp, Signal employees said that they had to remain at the camp. Signal also required Mangani to sign paperwork under which he agreed to pay for the tools that he used. Because the Signal employees threatened to send him back to India if he would not agree to this condition, Mangani signed the paperwork.
367. Mangani had been told by Dewan, Burnett, and Pol that he would earn the equivalent of 200,000 to 300,000 rupees (approximately $4,300 to $6,462) per month at Signal. Based on these assurances, he had expected that he would be able to repay his debts and repurchase his land. Only after signing the paperwork allowing Signal to deduct hundreds of dollars per week from his salary did Mangani realize how difficult it would be to realize these goals.
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368. On multiple occasions, Mangani observed Signal personnel threaten to suspend or deport workers who complained about the conditions at Signal or did not work hard enough. As a result, Mangani felt compelled to work quietly and without complaint. He was afraid of being sent back to India. Employers there did not pay enough for him to repay his debts, and he needed to support his family. He was also afraid that Dewan’s agents might retaliate against him if he returned to India.
369. In addition, Signal and the Agents continued to promise Mangani that he would receive a green card. For example, in or about early 2007, Mangani attended a number of meetings at which Signal officials, Burnett, and Dewan assured him and other workers that Signal would process their green cards.
370. Mangani relied upon Defendants’ promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants’ “recruitment fees,” his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would take adverse immigration action against him, Mangani felt intimidated into acquiescence and compelled to continue working for Signal.
Prakash Moses Kanagiah Manonmoni 371. In or about June 2006, Manonmoni saw an advertisement in an Indian newspaper announcing a program under which pipefitters could work in the United States and receive green cards. Manonmoni called the number in the advertisement and spoke to Salimon, who told him to attend an informational meeting in August 2006. 372. At this meeting, Salimon explained that Signal would process permanent residency visas for the workers. He stated that each worker would have to pay 850,000 rupees 80

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(approximately $18,700) plus airfare to the United States. Salimon asked interested workers to sign a contract at the meeting, and said that they would be contacted about a test and an interview. Manonmoni handed his signed contract to Dewan.
373. Later that month, Manonmoni was invited to an interview attended by Salimon, Dewan, Pol, and a Signal project manager. During this meeting, he also took and passed a written pipefitters’ examination.
374. Manonmoni ultimately paid Dewan, Pol, and Burnett 600,000 rupees (approximately $13,320) in “recruitment fees,” plus approximately 170,000 rupees (approximately $3,673) in travel and other expenses. In order to pay these fees, Manonmoni sold a parcel of land that he owned. He also took out two loans using his wife’s jewelry and his life insurance policy as collateral.
375. Just before Manonmoni flew to the United States, he traveled to Dewan’s office and paid his final payment. That day, Dewan assured Manonmoni that if he followed Signal’s rules, Manonmoni would receive a green card.
376. When Manonmoni arrived in the United States, he was told that Signal would deduct $245 a week from his salary for accommodations, regardless of whether he lived at the man camp. Because he could not afford to repay his loans and pay room and board twice, he felt that he had no choice but to live at the camp. Manonmoni was also afraid to leave Signal or complain about the conditions, because he knew that he could not return to India and still repay his loans.
377. In addition, Manonmoni believed that if he continued to work at Signal and do a good job, he would receive his green card. In or about December 2006, Manonmoni attended a camp meeting at which Burnett stated that Signal would secure visa extensions and green cards
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for the workers. In addition, throughout Manonmoni’s time at Signal, John Sanders told him and other workers that Signal would “take care” of their green cards.
378. Manonmoni relied upon Defendants’ promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants’ “recruitment fees,” his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would take adverse immigration action against him, Manonmoni felt intimidated into acquiescence and compelled to continue working for Signal.
Adharsan Manuel 379. In or about June 2006, Manuel saw an advertisement in an Indian newspaper offering positions for welders in the United States and the opportunity to receive a green card. Manuel called the number listed in the advertisement and spoke with Salimon, who told him to attend a meeting at a hotel. 380. During this meeting, at which Dewan, Salimon, and Pol were present, Dewan told Manuel and other prospective workers that they would travel to the United States on H-2B visas to work at Signal. Shortly thereafter, Manuel met with Dewan at his office, where Dewan explained that Manuel would also be able to receive a green card if he took the job at Signal. 381. On or about November 7, 2007, Manuel met with Salimon, Dewan, and Burnett to discuss his upcoming interview at the United States Consulate. They instructed Manuel not to mention Signal’s promise that he would receive a green card during his consular interview, though Dewan and Burnett assured him that it would be taken care of once he arrived in the United States.
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382. Manuel paid approximately 700,000 rupees (approximately $15,000) to Dewan, Pol, and Burnett for the opportunity to work for Signal. In order to raise this money, Manuel depleted his savings and secured a loan at approximately 4 percent interest by offering his sister’s and wife’s dowries as collateral.
383. After he arrived in the United States, Manuel learned for the first time that he had to pay $35 per day for accommodations that were much worse than any he had ever experienced.
384. Despite the squalid living conditions and the unsafe work environment, Manuel felt compelled to remain at Signal. He was afraid that if he left, he would be sent back to India and would not receive the green card he had been promised. Manuel believed that remaining at Signal was the only option that would allow him to repay his substantial debt, because he could never earn enough money to repay that debt in India. Manuel also felt compelled to remain because of Signal’s conduct. Signal foremen constantly monitored Manuel—even when he went to the bathroom—and threatened to notify the police and immigration officials if Manuel left Signal. Signal employee John Sanders threatened to send Manuel and other workers back to India if they complained about the conditions at the man camp. Manuel also feared that Signal employees or Dewan might retaliate against him or his family if he left or complained about the horrible conditions.
385. Manuel received repeated assurances from Signal personnel throughout early-tomid 2007 that he would receive his green card. In addition, in or about March 2007, Burnett and Dewan traveled to Signal and met with the workers, assuring them that Signal was processing their green cards.
386. Manuel relied upon Defendants’ promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work
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for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants’ “recruitment fees,” his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would take adverse immigration action against him, Manuel felt intimidated into acquiescence and compelled to continue working for Signal.
Jacob Mazhukkattu Mathew 387. In or about June 2006, J.M. Mathew read a newspaper advertisement offering temporary and permanent work visas and employment with a marine company in Mississippi and Texas. He called Dewan Consultants and spoke with Salimon, who invited him to a meeting at a hotel. 388. Approximately one week later, J.M. Mathew attended the meeting, where Dewan, Salimon, and Burnett were present. At this meeting, Burnett said that the workers would travel to the United States on H-2B visas. The workers would receive green cards after the H-2B visas had been extended. Dewan explained that this process would cost 600,000 rupees (approximately $13,000). After the presentation, J.M. Mathew spoke separately with Burnett, who assured Mathew that his wife could also come to the United States after he received a green card. An employee of Dewan Consultants also assured J.M. Mathew that he could bring his wife and family to the United States after obtaining a green card, which the employee claimed would occur within two years. J.M. Mathew also spoke with Salimon and asked him about the accommodations at Signal. Salimon said that two workers would share each room and that food and accommodations would be free. 389. Soon thereafter, J.M. Mathew took a skills test in the presence of Dewan, Salimon, and two Signal employees. The Signal employees supervised the test and told J.M. Mathew that he had passed. 84

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390. In order to raise the 600,000 rupees that J.M. Mathew paid to Dewan, Pol, and Burnett, J.M. Mathew’s mother-in-law borrowed 125,000 rupees (approximately $2,693), posting her home and land as collateral. J.M. Mathew mortgaged his home and land and borrowed the remainder at an interest rate of approximately 12 or 13 percent per year. J.M. Mathew paid Agents three fee payments in or about and between August and November of 2006.
391. In or about December 2006, J.M. Mathew traveled to Dewan’s office where he paid his final fee payment. There, he learned that Signal would deduct $35 per day from his paycheck for room and board. Although he believed that this amount was too high, he felt that he had no choice but to continue with the process because he had already paid Dewan, Burnett, and Pol a substantial amount of money that he could not recover.
392. In the United States, J.M. Mathew remained at Signal because he continued to believe that he would receive a green card. J.M. Mathew met regularly with Sanders and other Signal employees to discuss his immigration concerns, and he attended a number of meetings at which Signal and the Agents discussed green cards. In or about early 2007, Dewan spoke at two separate meetings and stated that workers would receive green cards. During this same time period, Burnett also came to Signal and promised the workers green cards. In addition, on or about March 8, 2007, a Signal Vice President called a meeting and assured Mathew and other workers that they would receive green cards soon.
393. J.M. Mathew was also afraid to leave Signal because if he returned to India, he would not be able to repay his debts and would lose his house and land, as well as his mother-inlaw’s house and land. He felt trapped. He could not travel from the man camp without transportation provided by Signal. He felt that he could not even criticize Signal’s treatment of himself and other Indian workers due to Signal’s threats of deportation.
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394. J.M. Mathew relied upon Defendants’ promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants’ “recruitment fees,” his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would take adverse immigration action against him, J.M. Mathew felt intimidated into acquiescence and compelled to continue working for Signal.
Johny Mathew 395. In or about March 2006, J. Mathew saw a newspaper advertisement in India offering welding jobs in the United States and the possibility of receiving a green card. J. Mathew called Dewan Consultants in response to the advertisement. 396. In or about May 2006, J. Mathew attended a meeting led by Dewan, Pol, Burnett, and Salimon. At this meeting, Dewan explained that workers would travel to the United States on 10-to-11 month H-2B visas, which would be extended three times. During this time, Signal would apply for green cards for the workers. Dewan also stated that the workers would eventually be able to settle permanently with their families in the United States. Visa and green card processing would cost 750,000 rupees (approximately $16,750). 397. In or about May or June 2006, J. Mathew attended and passed a skills test, at which both Salimon and Dewan were present. 398. J. Mathew later met with Burnett, who reiterated that J. Mathew would first receive an H-2B visa and would then get a green card. At this meeting, J. Mathew signed an agreement with Signal, which Salimon interpreted for him, and which J. Mathew believed to promise that he would receive a green card.
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399. J. Mathew ultimately quit his job and paid almost 700,000 rupees (approximately $15,633) to Dewan, Pol, and Burnett in approximately three installments. In order to raise this money, J. Mathew sold his wife’s wedding jewelry, used additional money that he had saved to buy a house, and took out a loan at 12 percent monthly interest. In or about the fall of 2006, J. Mathew refused a job in Kazakhstan so that he could stay in India and complete the necessary steps to receive his visa and green card.
400. In or about late November 2006, a few days before his flight to the United States, J. Mathew traveled to Dewan’s office. Dewan’s staff forced him to sign several documents in a rushed manner and did not give him time to read or understand the documents. Dewan also demanded that J. Mathew return to Dewan his copy of the original signed agreement that promised him a green card, as well any receipts and papers related to the Signal opportunity. When J. Mathew hesitated, Dewan said that J. Mathew would not be able to go to the United States unless he returned the documents. Dewan refused to give J. Mathew his passport and plane ticket until he returned these documents to Dewan.
401. After arriving at Signal, J. Mathew attended two or three meetings in or about early-to-mid 2007 at which Burnett promised that Signal would process the workers’ green cards. J. Mathew also attended a meeting, in or about March 2007, at which Dewan stated that the workers would receive green cards.
402. Despite these promises, J. Mathew was very unhappy at Signal. The living and working conditions were terrible, and Signal deducted $35 from his pay each day for room and board.
403. J. Mathew felt trapped and unable to leave Signal. He was afraid that if he were sent back to India, he and his family would be thrust into poverty because of the debt he had
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incurred. He was also afraid that he would suffer mistreatment at the hands of Dewan and his associates.
404. J. Mathew relied upon Defendants’ promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants’ “recruitment fees,” his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would take adverse immigration action against him, J. Mathew felt intimidated into acquiescence and compelled to continue working for Signal.
Nandhakumar Nagaraj 405. In or about May or June of 2006, a friend of Nagaraj told him about a newspaper advertisement offering the opportunity to obtain an H-2B visa and green card. Nagaraj responded to the advertisement and called Salimon. Salimon confirmed that Nagaraj and other workers could obtain H-2B visas and green cards and told Nagaraj to attend a meeting in approximately three weeks to learn more. 406. Dewan, Salimon, Burnett, and Pol were present at this meeting. They explained that workers would travel to the United States on H-2B visas, and that during this time, Signal would process their green card applications. 407. Approximately one month after the meeting, Nagaraj took a welding test administered by an American. Approximately one month after the test, Nagaraj met with Salimon at a hotel. Salimon told Nagaraj that he could obtain an H-2B visa and work in the United States for ten months. After ten months, Nagaraj would automatically receive a green card and could bring his family to the United States.
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408. Nagaraj ultimately paid Dewan, Pol, and Burnett 800,000 rupees (approximately $17,787) for this opportunity. Nagaraj borrowed approximately three-fourths of these fees at a monthly interest rate of 10 percent. He also depleted his savings and sold property and jewelry that his mother had received for her wedding from Nagaraj’s grandfather.
409. Just before Nagaraj left for the United States, he traveled to Dewan’s office in Mumbai. Dewan refused to give Nagaraj his passport until Nagaraj had paid the final installment and signed various documents. Nagaraj asked if he could read the documents, but Dewan refused and insisted that Nagaraj sign quickly so that he would not miss his flight to the United States.
410. After arriving in the United States, Nagaraj learned that Signal would deduct $245 from his paycheck each week for room and board. When he asked Signal employees if he could live outside the man camp, he was told that he was not permitted to live elsewhere. Nagaraj felt compelled to remain at Signal’s man camp because he would not be able to repay his substantial debt if he was required to pay additional money for housing and food.
411. Nagaraj attended a meeting in which Dewan promised Nagaraj and other Indian workers that they would receive green cards if they continued to work at Signal.
412. Nagaraj relied upon Defendants’ promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants’ “recruitment fees,” his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would take adverse immigration action against him, Nagaraj felt intimidated into acquiescence and compelled to continue working for Signal.
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Shaji Veluthalakuzhiyil Nanoo 413. In or about April or May of 2006, Nanoo saw a newspaper advertisement placed by Dewan Consultants offering the opportunity for welders and pipefitters to work in the United States, and promising green cards and legal status for the workers and their families. Nanoo called the phone number listed in the advertisement and spoke to Salimon. Salimon said that the opportunity would include green card processing and that the process would cost 530,000 rupees (approximately $11,850). 414. In or about May 2006, Nanoo traveled to Cochin, India for an interview and skills test attended by Salimon and Dewan. At the interview, Salimon said that Signal would apply for Nanoo’s green card once he arrived in the United States. Soon thereafter, at a meeting attended by Pol, Burnett, Dewan, and Salimon, Burnett also assured Nanoo that Signal would begin to process his green card once he arrived in the United States. 415. Nanoo faced considerable difficulties raising the money that he ultimately paid to Dewan, Pol, and Burnett. He mortgaged his land at approximately 12 percent interest and used jewelry belonging to his wife, sister, and sister-in-law as collateral for an additional loan. He also sold more family jewelry. Nonetheless, he was still unable to raise the total amount required. 416. Before he was scheduled to leave for the United States, Nanoo visited Dewan’s office to pay his final fee installments and collect his ticket. Nanoo signed various documents, but because Dewan’s assistants rushed him, he did not have a chance to read or understand what he was signing. 417. Before Nanoo was able to collect his ticket and passport, Dewan’s assistants determined that Nanoo still owed a portion of his fees. Dewan refused to give Nanoo his passport until he had paid the remainder of the fees. Nanoo called his brother-in-law, who 90

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helped him raise some additional money. Only after Nanoo paid the full amount demanded by the Agents was he allowed to board the next flight to the United States.
418. In the United States, Nanoo learned that Signal would deduct $245 per week for food and housing from his paycheck, regardless of whether he lived in the man camp. Despite the terrible living conditions, the fees that Signal charged him made it prohibitively expensive to live elsewhere.
419. Nanoo’s debt also made him feel compelled him to continue to endure the unsafe working conditions at Signal. Once, after Nanoo complained that the ships he worked on were unsafe, a Signal foreman suspended Nanoo for six days without pay. Nanoo knew that other Indian workers had experienced threats, retaliation, and deportation when they expressed their concerns about the conditions. Nanoo feared that if he were sent back to India, he would not be able to repay his debt, he would lose the land that he had mortgaged, and he and his family would become homeless. He was also worried that Dewan or his associates would hurt him or his family.
420. Nanoo relied upon Defendants’ promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants’ “recruitment fees,” his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would take adverse immigration action against him, Nanoo felt intimidated into acquiescence and compelled to continue working for Signal.
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Mangalan Chandrasekharan Pillai 421. In or about June 2006, M. Pillai saw an advertisement in a Dubai newspaper offering the opportunity for pipefitters to work in the United States and receive green cards. The advertisement invited interested workers to attend a meeting at a Dubai hotel. 422. At this meeting, Dewan explained that Signal was looking for Indian workers to travel to the United States under H-2B visas to repair oil rigs. The H-2B visas would be renewed two to three times. After that, the workers would receive green cards and would be able to bring their families to the United States. Dewan also explained that workers would be required to pay Burnett, Pol, and Dewan visa and green card processing fees. 423. M. Pillai later took a skills test. When he was notified that he had passed, he returned to the hotel. There, Dewan gave him a letter stating that M. Pillai would receive an H2B visa and green card in exchange for processing fees. 424. M. Pillai ultimately paid approximately 600,000 rupees (approximately $13,056) to Burnett, Pol, and Dewan. In order to raise this money, M. Pillai pawned his mother’s and wife’s jewelry and borrowed money from a friend. M. Pillai also took out two loans at 7 to 10 percent monthly interest, and an additional loan at 18 percent annual interest. 425. In or about November 2006, M. Pillai traveled to Dewan’s office to pay the final installments of his fees and receive his passport. After he gave the money to Dewan’s brother, Dewan’s associates rushed him out of the office before he could ask any questions or ask for a receipt. 426. After arriving in the United States, M. Pillai learned for the first time about the terrible living and working conditions and the substantial deduction that Signal took from each worker’s paycheck for accommodations. M. Pillai did not complain about the living and working conditions, however, because he saw that Signal threatened to deport workers who 92

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“caused trouble.” M. Pillai also feared that if he were sent back to India, he would be unable to repay his debts. He had attended meetings in which Signal officials had promised that the workers would receive green cards, and he believed that his continued employment in the United States was the only way he could repay his debts.
427. M. Pillai relied upon Defendants’ promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants’ “recruitment fees,” his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would take adverse immigration action against him, M. Pillai felt intimidated into acquiescence and compelled to continue working for Signal.
Radhakrishna Pillai Sivarama Pillai 428. In or about May 2006, R. Pillai saw an advertisement in a local Indian paper offering job opportunities for pipefitters in the United States. He called the number in the advertisement and eventually met with Salimon. Salimon told R. Pillai that Signal would begin his green card application when he arrived in the United States, and that the process would take approximately ten months. 429. In or about June or July 2006, R. Pillai traveled to Cochin, India for an interview and skills test. Salimon and another representative of Signal reaffirmed that Signal would apply for R. Pillai’s green card. 430. R. Pillai also attended a meeting in October 2006, at which Salimon, Dewan, and at least one other Agent were present. They explained that as soon as the workers began working in the United States, Signal would begin their green card applications. The process would take approximately ten months, at the end of which the workers would be able to bring their families 93

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to the United States. At the October meeting, R. Pillai was required to sign several documents. The Agents told him that he had to sign each document to come to the United States, but they did not explain the contents of the documents, and R. Pillai did not understand what they said.
431. R. Pillai left a well-paying job as a pipe-fitting supervisor and ultimately paid Pol, Burnett, and Dewan approximately 900,000 rupees (approximately $19,855) in “recruitment fees.” To raise the money for these fees, R. Pillai took out three loans at 8.5 percent monthly interest, secured by his brother’s house and all of his family’s jewelry.
432. On or about November 17, 2006, R. Pillai met with Dewan to collect his plane ticket. At this meeting, he signed additional documents that were not explained to him. Dewan also demanded that R. Pillai relinquish all of his documents relating to the Signal opportunity. Fearing that he would lose all the money he paid to Dewan and would not be able to work at Signal, R. Pillai complied.
433. When he arrived in the United States, R. Pillai was appalled by the unsanitary living conditions, the unsafe work environment, Signal’s discriminatory behavior, and the substantial fees Signal required him to pay for room and board. He also developed a bad cough from sleeping near the ventilator in his trailer, which still bothers him to this day. R. Pillai felt he had no choice but to endure these conditions and continue to work for Signal, however, because he was afraid that if he complained, he would be sent back to India, where he would be unable to repay the debt he had incurred to pay Dewan, Pol, and Burnett. Signal officials also continued to promise him that they would process all of his paperwork.
434. R. Pillai relied upon Defendants’ promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by
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Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants’ “recruitment fees,” his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would take adverse immigration action against him, R. Pillai felt intimidated into acquiescence and compelled to continue working for Signal.
Aby Molathu Poulose 435. In or about March or April of 2006, A. Poulose saw an advertisement in a Dubai newspaper that promised an opportunity to work in the United States and to obtain an H-2B visa and a green card. A. Poulose called Dewan Consultants and was told to attend a meeting in Dubai. 436. At that meeting, Dewan explained that workers hired by Signal would travel to the United States on H-2B visas and would receive green cards within nine to nineteen months. Dewan explained that this process would cost 700,000 rupees (approximately $15,764) and that, in the United States, the workers would earn 250,000 rupees (approximately $5,630) per month after taxes. Dewan also told A. Poulose that workers from Signal would be coming to India to administer employment tests. 437. Soon after the meeting, A. Poulose called Dewan to ask if he could meet Signal’s representatives in India for the job testing. Dewan agreed. 438. At the test, Signal personnel explained to A. Poulose that Signal was the “number one shipyard” in America and that Signal had sufficient political power that A. Poulose need not to worry about his visa. They also assured A. Poulose that Signal would apply for his green card and that it would be processed while A. Poulose was working in the United States. 439. In or about August 2006, A. Poulose attended another meeting at which Burnett, Dewan, and Salimon were present. Burnett told A. Poulose and other workers that he was a
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famous immigration lawyer and that 600 H-2B visas with green cards had been approved for Signal.
440. A. Poulose ultimately left his job in Dubai and paid almost 800,000 rupees (approximately $18,061) to Dewan, Pol, and Burnett. In order to raise this sum, A. Poulose borrowed 300,000 rupees (approximately $7,038) at 11 percent interest using his parents’ house and land as collateral. Because he was unable to secure money elsewhere, A. Poulose and his family eventually sold this property to finance the balance of his “recruitment fees.” Nonetheless, by the time he was scheduled to depart for the United States, A. Poulose still needed to raise an additional 20,000 rupees (approximately $450).
441. On the morning of A. Poulose’s flight to the United States, Dewan threatened to burn A. Poulose’s passport unless A. Poulose paid the missing 20,000 rupees. He stated that he would not refund any of the money that A. Poulose had paid. A. Poulose ultimately paid the full amount after his father offered Dewan the money that he intended to use to pay rent that month.
442. Before Dewan gave A. Poulose his passport, he required A. Poulose to sign paperwork. A. Poulose did not have time to read the documents because his flight would leave soon.
443. After arriving in the United States, A. Poulose felt compelled to remain at Signal. His H-2B visa prevented him from working for another employer in the United States, and he could not earn enough money to repay his debts if he returned to India. He also believed Defendants’ continued assurances that he would obtain a green card. Consequently, he felt that he had no choice but to continue working for Signal, despite the deplorable conditions.
444. A. Poulose relied upon Defendants’ promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work
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for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants’ “recruitment fees,” his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would institute adverse immigration action against him, A. Poulose felt intimidated into acquiescence and compelled to continue working for Signal.
Justin Poulose 445. In or about the summer of 2006, J. Poulose was working as a welder in Kerala, India, when he saw a newspaper advertisement offering jobs for welders and pipefitters at Signal. The advertisement mentioned green cards and said that workers could obtain visas that would allow them to travel to the United States immediately. J. Poulose called the phone number listed in the advertisement and spoke to Salimon. Salimon told J. Poulose that he could learn more about the immigration process and job opportunity at a meeting. 446. J. Poulose attended the meeting that week. He met with Pol, who was introduced an official of the American company recruiting workers. He also met with Dewan and Salimon. Pol explained that J. Poulose could work for Signal. Pol said that J. Poulose would travel to the United States on an H-2B visa and would obtain permanent residency status within one year, at which point he would be able to bring his family. Pol also stated that J. Poulose could earn around $16 to $19 per hour at Signal. 447. At the meeting, Dewan and Salimon explained that this process would cost 800,000 rupees (approximately $18,000). J. Poulose felt that this would be a good opportunity, but he was worried that he would not be able to afford the fees. 448. Approximately four to six weeks later, a woman from Salimon’s office called J. Poulose. She explained that the fees could be reduced to 650,000 rupees (approximately $14,163). She told J. Poulose that he should obtain the money and take a skills test. J. Poulose 97

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was hesitant, but based on the salary he had been promised, he believed that he would be able to afford the lower price and repay his debts.
449. On or about July 5, 2006, J. Poulose took and passed a skills test administered by Signal representatives. Dewan and Salimon were also present. Dewan said that J. Poulose would be able to receive permanent residency status in the United States. At a later meeting, Salimon also gave J. Poulose a letter promising employment at Signal, an H-2B visa, and permanent residency.
450. To raise the 650,000 rupees that he paid to Dewan, Pol, and Burnett, J. Poulose took out multiple loans, including two with monthly interest rates of approximately 10.5 percent. He used his mother’s wedding jewelry as collateral for one of these loans, and the deeds to his family’s house and land as collateral for the other. He also took out a third loan with a monthly interest rate of approximately 6 percent. J. Poulose paid all three fee installments totaling approximately 650,000 rupees by November 2006.
451. On the morning of J. Poulose’s flight to the United States, he traveled to Dewan’s office in Mumbai to obtain his passport. The office was crowded, and J. Poulose was forced to wait in a long line before he could meet with anyone. Eventually, J. Poulose met with a Dewan Consultants employee who insisted that J. Poulose quickly sign paperwork written in English. The employee rushed J. Poulose to sign and did not give him time to read the documents, emphasizing that his flight would leave soon and that there were several people in the office. At the same time, J. Poulose saw Dewan threaten a worker who did not have enough money to make his final payment to Dewan. Dewan told the worker that he could not go to the United States and stapled his passport shut. This made J. Poulose nervous, and he felt pressured
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to sign immediately. Only after he signed the documents did he receive his passport and plane ticket.
452. After J. Poulose arrived in the United States, he learned that Signal was deducting $35 per day from his paycheck. Signal’s camp manager informed J. Poulose that the company would deduct this amount from his wages even if J. Poulose lived outside of the man camp. Because he could not afford to repay his substantial debt and pay room and board outside the man camp with these deductions, J. Poulose felt compelled to remain at the man camp.
453. Months later, Signal held a camp meeting where Dewan, Burnett, Sanders, Snyder, and other officials were present. Both Dewan and Burnett assured J. Poulose and other workers that they would receive their visa extensions and that Signal would continue with their green card processing. Dewan warned, however, that the workers had to follow Signal’s instructions at all times if they did not want to be deported. After this meeting, J. Poulose feared that if he did anything to make Signal management unhappy, he would be deported and would not be able to repay his debts. This caused J. Poulose to suffer severe mental stress.
454. On or about March 10, 2007, J. Poulose attended a camp meeting led by John Sanders. Sanders assured J. Poulose and other workers that if they followed Signal’s rules, they would receive green cards. However, if they organized against Signal, then they would not be able to stay. After the meeting, J. Poulose saw notices on the man camp’s notice board instructing workers to bring documents to an office at the camp in order to obtain green cards. J. Poulose followed these instructions, and as a result believed that his visa would be extended.
455. In or about July of 2007, J. Poulose again met with Burnett. Burnett told J. Poulose that if he continued to work for Signal, his H-2B visa could be extended, and it would
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eventually be possible to file a green card application. Based on this promise, J. Poulose continued to work at Signal.
456. J. Poulose relied upon Defendants’ promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants’ “recruitment fees,” his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would institute adverse immigration action against him, J. Poulose felt intimidated into acquiescence and compelled to continue working for Signal.
Appunni Arul Prakash 457. In or about April of 2006, Prakash’s wife told him about a job advertisement offering work as a welder or fitter in the United States and the opportunity to obtain a green card within 18 to 24 months. Prakash called Dewan Consultants and spoke to a representative who said that he could work at Signal and obtain a green card. The representative said that this process would cost about 700,000 rupees (approximately $15,650), and invited Prakash to attend a general meeting in May. 458. At the May 2006 meeting, Dewan explained that Prakash and other workers would work for Signal. Pol stated that Signal would file for green cards within 18 to 24 months, and that after the workers received their green cards, they would return to India then go back to America with their families. Pol and Dewan also assured those at the meeting that the green card processing would proceed as promised. Pol stated that this process would cost workers 700,000 rupees (approximately $15,650); Salimon repeated this price as well.
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459. In or about August 2006, Prakash attended another meeting where Dewan, Salimon, and Burnett were present. Burnett explained that Prakash would receive a green card within 24 months and that he could bring his family to the United States.
460. In or about November 2006, Prakash attended another meeting with Burnett, Dewan, Salimon, and Sanders. Burnett explained that Prakash would travel to the United States on an H-2B visa, which Signal would extend twice. Prakash would then receive a green card. Sanders also assured Prakash that Signal would take care of his visa.
461. Prakash ultimately paid the 700,000 rupees demanded by the Agents. To raise this money, Prakash’s family mortgaged their home and land in exchange for a loan of about 400,000 rupees (approximately $9000) at twelve percent monthly interest. Prakash obtained another loan of approximately 100,000 rupees (approximately $2,250) at a monthly interest rate of approximately 23 percent. He also borrowed 150,000 to 200,000 rupees (approximately $3300 to $4500) at 9 or 10 percent interest using as collateral jewelry that his wife and sister had received for their weddings, and that had significant sentimental value.
462. On the day of Prakash’s flight to the United States, he traveled to Dewan’s office in Mumbai to obtain his passport and plane ticket. Dewan demanded that Prakash return to Dewan his copies of original signed agreements. When Prakash resisted, Dewan threatened that Prakash would not receive his passport or plane ticket. While Prakash was waiting at the office, he saw Dewan threaten to burn another worker’s passport until that man paid Dewan the remaining money that Dewan demanded. Prakash therefore feared that he would not be able to travel to the United States unless he gave Dewan his paperwork. Prakash gave Dewan all of his original documents. Dewan then insisted that Prakash sign paperwork written in English if Prakash wanted to receive his passport or plane ticket. Dewan also demanded that Prakash give
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him all of his paperwork relating to the Signal opportunity. When Prakash resisted, Dewan said that unless Prakash complied, he would withhold Prakash’s passport and Prakash would not receive a refund for the money he had already paid. Prakash feared that he would lose this money and miss his flight, so he gave Dewan the documents he had with him and quickly signed the paperwork without understanding what it said.
463. Although Prakash knew Signal would be deducting money from his paycheck for room and board before he left India, he did not realize until he arrived at Signal that the amount to be deducted was almost $1,050 per month. Because of Prakash’s heavy debt burden and because he would have to pay this amount even if he lived outside of the man camp, he felt that he had no choice but to continue living at the man camp. Prakash also felt compelled to remain at Signal because Signal assured him that he could obtain a green card if he stayed and performed well. In particular, in or about March 2007, Prakash attended a meeting at which Burnett told the workers that if they behaved well and worked hard, they would receive green cards. If they caused trouble, however, they would be fired. Prakash feared being sent back to India, because he believed that he would not be able to earn enough money there to repay his debts.
464. Prakash relied upon Defendants’ promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants’ “recruitment fees,” his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would soon adverse immigration action against him, Prakash felt intimidated into acquiescence and compelled to continue working for Signal.
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Nibu Raju 465. In or about May or June of 2006, Raju was in India on a break from his job in Dubai when he saw a newspaper advertisement offering the opportunity to work as a welder or fitter in the United States and obtain and H-2B visa and permanent residency. Raju called the phone number listed on the advertisement and spoke to an employee of Aravind Associates, a sub-agency of Dewan Consultants. The employee informed Raju that he would travel to United States on an H-2B visa and would then obtain a green card that would allow him and his family to become permanent residents of the United States. She told Raju to call Salimon the next day for additional information. 466. Raju called Salimon, who reiterated that Raju could work in the United States and obtain an H-2B visa and permanent residency. When Raju explained that he would soon return to Dubai for work, Salimon told Raju to contact Dewan Consultants’ Dubai office and attend an interview in Dubai in June. 467. Raju attended the interview, at which Dewan and two Signal employees were present. Raju took a written test, which a Signal employee informed him that he had passed. 468. Raju also spoke with Dewan, who explained that Raju would travel to the United States on an H-2B visa, and that Raju’s employer, Signal, would handle Raju’s green card processing. Dewan also explained this process would cost approximately $18,000. 469. Between approximately June and November 2006, Raju paid this amount in installments to Pol, Burnett, and Dewan. To raise this money, Raju and his family borrowed 600,000 rupees (approximately $13,068) from a bank, at a monthly interest rate of approximately 7.5 percent. Raju also borrowed about 100,000 rupees (approximately $2,179) from a friend, at a monthly interest rate of approximately 3 percent. Raju borrowed additional money from another
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friend. To pay the remainder of the fees, Raju sold his mother’s and cousin’s gold jewelry, including jewelry that his mother had received as a wedding gift.
470. On or about August 22, 2006, Raju met with Dewan and Burnett at Dewan’s Dubai office. Dewan introduced Burnett as Signal’s lawyer. Burnett explained that Raju and other workers would obtain green cards and be able to bring their families to the United States. As a result, Raju signed an agreement that day.
471. On or about August 29, 2006, Raju traveled to Dewan’s Dubai office to pay a fee installment. Raju again asked Dewan if he would receive a green card, and Dewan assured Raju that he would.
472. On or about November 7, 2006, the day before Raju’s interview at the United States Consulate, Raju met with Salimon and Dewan. Dewan repeatedly told Raju that he would not receive a refund if he failed his interview. After the interview, Dewan emphasized that Raju must pay the remainder of the money that he owed Dewan in order to go to the United States.
473. In or about the middle of November of 2006, Salimon called Raju and told him to be ready to travel to United States on November 29, 2006. Salimon told Raju to bring his final fee installment and all the documents relating to the job at Signal to Dewan’s Mumbai office.
474. On or about November 29, 2006, Raju traveled to Dewan’s office in Mumbai. Approximately 50 other Indian workers were waiting, and Dewan called each worker individually into a room. When Raju met with Dewan, Dewan required Raju to sign a number of documents. Dewan refused to give Raju time to read the documents and emphasized he would miss his flight unless he signed quickly. Dewan also demanded that Raju give Dewan all of his documents relating to the Signal opportunity. Raju refused at first, but Dewan told him that he could not travel to the United States unless he gave Dewan the paperwork. Because he had
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already given Dewan so much money and had mortgaged his parents’ home, Raju felt that he had no choice but to sign the documents and give Dewan his paperwork. Dewan then gave Raju his passport, and Raju left for the airport and flew to the United States.
475. After arriving in Mississippi, Signal employees and officials repeatedly promised Raju that he would receive a green card. For example, when Raju explained to his foreman that he had incurred substantial debt to work at Signal, the foreman assured Raju that Signal would apply for a green card for him. Raju also attended several meetings at which Burnett and John Sanders promised the workers green cards. During a meeting in or about January or February of 2007, Dewan and Burnett told the workers that they would receive green cards and urged the workers to continue working at Signal. On or about March 8, 2007, Sanders and other Signal officials, including Signal’s Vice President, held another meeting. The Signal officials told Raju and other workers that they would receive green cards. Based on these repeated promises of green cards and the substantial debt he had incurred to finance his trip to the United States, Raju continued working at Signal.
476. Raju also felt compelled to continue living at the man camp because Signal deducted $35 each day from his paycheck for room and board, which made it financially impossible for Raju to live elsewhere. Signal officials told Raju that he could go back to India if he did not like living at the man camp.
477. Several months after Raju began working at the man camp, Signal told him and other workers that Signal would re-test all the Indian workers. If anyone failed their test, Signal would reduce their salary by one-half.
478. After the March 2007 incident during which a number of workers were deported, Raju began to fear that Signal would deport him. He told his father about the incident, and his
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father called Salimon. Salimon threatened Raju’s father, saying that if he continued to ask questions, Raju would experience the same fate as the worker who had tried to commit suicide. When Raju’s father told Raju about his conversation with Salimon, Raju became even more afraid that Signal would arrange for his deportation.
479. Raju relied upon Defendants’ promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants’ “recruitment fees,” his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would soon adverse immigration action against him, Raju felt intimidated into acquiescence and compelled to continue working for Signal.
Sreenivasarao Raparthy 480. On or about June 26, 2006, Raparthy learned from a friend about newspaper advertisements offering the opportunity to work as a welder or pipefitter at an American shipyard. In response to the advertisement, Raparthy attended an interview session, where Dewan and Burnett were present. At the interview session, Dewan and Burnett told him that if he worked in the United States, he could obtain an H-2B visa and then a green card. 481. The same day, Raparthy took a written test administered by Signal employees. Raparthy passed the test, and the employees gave him paperwork promising an H-2B visa and permanent residency. 482. Approximately three days later, Raparthy attended a meeting with Dewan. At that meeting, Dewan assured Raparthy that he could travel to the United States on an H-2B visa. Dewan also told Raparthy that an H-2B visa extension and a green card application would be
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filed without Raparthy needing to take additional steps. Dewan gave Raparthy a document signed by Burnett, which promised an H-2B visa and permanent residency.
483. Following Dewan’s instructions, Raparthy paid approximately 600,000 rupees (approximately $12,500) to Dewan, Burnett, and Pol. To raise the money for these fees, Raparthy borrowed approximately 150,000 rupees from a bank at three percent monthly interest using his wife’s and mother’s gold jewelry as collateral. He borrowed another 300,000 rupees at six percent monthly interest. He borrowed the balance from friends.
484. On the day of his flight to the United States, Dewan’s agents insisted that Raparthy sign additional paperwork if he wanted to receive his passport or plane ticket. Raparthy asked if he could read the paperwork but was told that he would miss his flight if he reviewed the paperwork. Raparthy signed, and only then received his passport and ticket.
485. After Raparthy arrived in the United States, he discovered that Signal deducted approximately $245 from his paycheck each week for room and board. Raparthy asked Darrell Snyder and other Signal management if he could live outside the man camp, but Snyder told Raparthy that Signal would deduct the amount from his paycheck even if he lived elsewhere. Raparthy felt compelled to continue living at the man camp because he could not afford to repay his debt if Signal continued to deduct room and board and he paid for rent elsewhere.
486. Raparthy relied upon Defendants’ promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants’ “recruitment fees,” his fear that Signal would confiscate even more of his hard-earned wages,
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and his fear that Signal or Burnett would institute adverse immigration action against him, Raparthy felt intimidated into acquiescence and compelled to continue working for Signal.
Balwinder Singh 487. B. Singh was recruited in or about 2006. 488. During meetings with Dewan and Burnett in India in or about mid-2006, Dewan and Burnett made numerous representations that led B. Singh to believe that in exchange for paying thousands of dollars in “recruitment fees,” Signal and the Agents would assist B. Singh with applying for and receiving permanent residency in the United States. 489. In reliance on these promises, B. Singh incurred substantial debt and paid thousands of dollars in “recruitment fees” to Dewan, Burnett, and Pol. 490. After arriving in the United States, B. Singh felt compelled to remain at Signal’s man camp despite crowded housing because, among other reasons, Signal would deduct living expenses from his paycheck even if he lived elsewhere, his H-2B visa did not permit him to work for another U.S. employer, Signal constantly monitored the workers and threatened to deport them if they complained about the horrible conditions at Signal, and he believed that he would face financial ruin and bankruptcy if he returned to India. 491. B. Singh relied upon Defendants’ promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants’ “recruitment fees,” his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would institute adverse immigration action against him, B. Singh felt intimidated into acquiescence and compelled to continue working for Signal.
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Ranjit Singh 492. In or about May or June of 2006, R. Singh saw an advertisement in a Dubai newspaper for a welding job at Signal. The advertisement included Dewan Consultants’ name and stated that permanent residency visas would be available for workers and families. R. Singh called Dewan’s office and spoke with one of his employees, who told R. Singh to travel to the New Delhi office with 40,000 rupees (approximately $873) to apply for the job. 493. At Dewan’s office, Dewan’s employee explained to R. Singh and approximately twelve other applicants that they would travel to the United States on a visa, which would be extended, and that Signal would obtain green cards for the workers within two or three years. The employee assured them that American lawyers would handle the permanent residency visa process. The employee also explained that the process would cost between 650,000 and 700,000 rupees (approximately $14,000 and $15,000) after travel expenses. At another meeting approximately two weeks later and in subsequent conversations, the employee explained that R. Singh would pay the fees to Dewan, Burnett, and Pol. 494. R. Singh paid these “recruitment fees” in approximately three installments in or about and between May and October of 2006. To raise the money for the fees, R. Singh emptied his savings, borrowed money from friends and his wife’s parents, and sold his wife’s jewelry. R. Singh’s father also gave up title to two acres of property, which included his farm and home, in exchange for loans of totaling approximately 400,000 rupees (approximately $8,800). 495. After R. Singh had raised the money needed to pay the fees, he met with Dewan and Burnett. They both assured R. Singh that he would receive a green card. 496. In or about October 2006, R. Singh quit his job in Dubai in order to attend his interview at the United States Consulate.
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497. Just before R. Singh’s flight to the United States, Dewan forced him to sign several papers in English, which R. Singh does not speak or read. Dewan and his employee assured him that the papers were related to legal work. Dewan refused to explain to R. Singh what he was signing. R. Singh only received his passport back after he signed this paperwork.
498. R. Singh was appalled by the horrible conditions at Signal. Nonetheless, he knew that he would not be able to repay the money he had borrowed if he returned to India. He felt that he had no choice but to stay at Signal and wait to receive the green card that Signal and its Agents continued to promise. In particular, in or about July 2007, Signal officials and Burnett led a meeting at which they told the workers that they would apply for the workers’ visa extensions and green cards.
499. R. Singh relied upon Defendants’ promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants’ “recruitment fees,” his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would institute adverse immigration action against him, R. Singh felt intimidated into acquiescence and compelled to continue working for Signal.
Savinder Singh 500. In or about April or May of 2006, S. Singh was working in the UAE when he saw an advertisement promising the opportunity to work in the United States and obtain a green card. S. Singh called Dewan Consultants and spoke with someone who invited him to attend a meeting at Dewan Consultants’ office.
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501. In or about May of 2006, S. Singh traveled to Dewan Consultants’ UAE office and spoke with Dewan’s sister, who told him that Signal workers would travel to the United States on a green card and that Dewan Consultants would help him obtain permanent residency.
502. On or about May 25, 2006, S. Singh took and passed a welding test at which Dewan, Pol, and a Signal employee were present. A few days later, S. Singh met with Dewan at his UAE office. Dewan told S. Singh that he would receive a green card after arriving in the United States.
503. At the May 2006 meeting, Dewan told S. Singh that the visa and green card process would cost approximately $11,250. However, Dewan, Pol, and Burnett ultimately demanded approximately $14,250. S. Singh paid this amount in installments. To obtain the money, S. Singh borrowed money from friends, gave the title to his home as collateral to obtain a large loan, and depleted his life savings.
504. In or about October 2006, S. Singh met with Dewan and Burnett, who told him to tell U.S. consular officials that he was only traveling to the United States on a temporary basis. During this conversation, Dewan again assured S. Singh that he would receive a green card if he followed their instructions.
505. On or about October 30, 3006, S. Singh traveled to Dewan’s office in Mumbai to collect his ticket and passport. Dewan demanded that S. Singh sign several documents written in English, which S. Singh could not read. Dewan also demanded that S. Singh give him the paperwork regarding his “recruitment fees.” When S. Singh resisted, Dewan told him that he would lose the money that he had paid and his passport if he did not comply. Because he had incurred so much debt, S. Singh felt that he had no choice but to comply. Only after S. Singh relinquished his paperwork, signed the documents, and gave his final payment to Dewan did
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Dewan give S. Singh his passport. Dewan assured him that Malvern Burnett would process S. Singh’s green card.
506. After his arrival in Mississippi, S. Singh repeatedly inquired about his green card. Approximately every two weeks until he left Signal on or about December 17, 2008, S. Singh met with Signal employees, including John Sanders, who told him that if he listened to Signal’s instructions, he would receive a green card. In addition, on or about March 8, 2007, S. Singh attended a meeting at which Signal’s Vice President, Snyder, and Burnett told S. Singh that they would process his green card application. Approximately two months later, S. Singh complied with a notice that Signal had posted at the man camp stating that workers should submit copies of their I-94 forms and passports for green card processing.
507. S. Singh felt compelled to remain at Signal in order to recoup the money he had paid in “recruitment fees.” In addition, S. Singh felt compelled to live at man camp because Signal would deduct approximately $245 each week for room and board regardless of whether he lived at the man camp. S. Singh was also afraid that if he complained, he would lose his job and be sent back to India. In or about March of 2007, Dewan traveled to the man camp and instructed S. Singh not to complain about the conditions at Signal. Around the same time, S. Singh learned that Dewan had threatened another worker’s family in India. S. Singh feared that he and his family might be hurt if he complained about the conditions at Signal or did not follow Signal’s instructions. Signal employees also threatened to deport him if he caused problems. S. Singh had no friends or family in the United States and felt that he had no choice but to endure the conditions at Signal if he wanted to repay his debts.
508. Signal’s assurances that S. Singh would receive a green card continued into 2008. In or about March of 2008, Snyder and Signal attorney Patricia Bollman assured S. Singh that
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Signal was processing S. Singh’s green card extension and that he would receive an H-2B visa extension. In or about November 2008, Signal representatives told S. Singh that if he helped Signal by signing an affidavit supporting the company, Signal would complete the paperwork necessary for S. Singh to obtain a green card. Signal’s translator, Ramesh Gunisetti, told S. Singh that the document stated that S. Singh had not paid any money to Pol, Burnett, or Dewan to obtain his immigration paperwork. S. Singh could not read English sufficiently to understand the affidavit, but he felt compelled to sign because he feared that if he did not, he would be deported and would not be able to repay his debts. S. Singh later learned that this affidavit stated that he was very happy working at Signal and that he could read, write and speak English.
509. S. Singh relied upon Defendants’ promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants’ “recruitment fees,” his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would institute adverse immigration action against him, S. Singh felt intimidated into acquiescence and compelled to continue working for Signal.
Shanmugam Subramanian 510. In or about 2006, Subramanian was working as a pipefitter in Singapore when a friend in India sent him a newspaper advertisement offering jobs in the United States. It stated that workers would travel to the United States on H-2B visas and would then receive green cards. Subramanian quit his job in Singapore and traveled to India to respond to the advertisement. He arrived in India in or about April 2006. 511. In India, Subramanian attended a meeting where he met Salimon and filled out an application. He later met Pol, Dewan, and Salimon for an interview. After the interview, 113

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Salimon assured Subramanian that if he was selected and accepted the job, Signal would apply for his green card once he arrived in the United States. Salimon soon called Subramanian to tell him he had been selected for the job.
512. Soon thereafter, Subramanian met with Salimon, who gave him a document stating that Subramanian would need to pay Dewan, Pol, and Burnett a series of payments totaling over 600,000 rupees (approximately $13,200).
513. Subramanian paid all the fees demanded by the Agents. In order to pay these fees, Subramanian used the money he had saved from his job in Singapore and pledged his mother’s and sister’s jewelry as collateral in exchange for a loan of 350,000 rupees (approximately $7,700) at 5 percent monthly interest. Subramanian also turned down a job opportunity in Canada, because he felt obtaining a United States green card would offer him better work opportunities.
514. The day before Subramanian flew to the United States, he travelled to Dewan’s office in Mumbai to make his final payment. However, Dewan told him that he still owed approximately 10,000 to 15,000 rupees. Dewan informed Subramanian that if he did not pay this amount immediately, he would not receive his visa, passport, or plane ticket. Dewan also informed him that he would not receive a refund for the money he had already paid. Subramanian called a friend in Mumbai, who was able to raise the missing amount. Only then did Dewan allow Subramanian to fly to the United States.
515. When he arrived at Signal, Subramanian was appalled at the squalid living conditions. He also learned that approximately $1,050 per month would be deducted from his wages, regardless of whether he chose to live at the man camp. Subramanian felt that he had no choice but to stay with Signal, however, because he needed to repay the substantial debts he had
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incurred in order to take the job. Subramanian was afraid to complain about the living and working conditions because he knew that Signal fired workers who complained.
516. At Signal, Subramanian attended meetings with Signal officials approximately once each month. At those meetings, Signal officials repeatedly assured Subramanian and other Indian workers that Signal would apply for their green cards.
517. Subramanian relied upon Defendants’ promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants’ “recruitment fees,” his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would institute adverse immigration action against him, Subramanian felt intimidated into acquiescence and compelled to continue working for Signal.
Ninan John Tharakan 518. In or about May 2006, Tharakan was working in Dubai when a friend told him about an advertisement offering pipefitting jobs in the United States. Tharakan called the number that his friend gave him and spoke with a representative of Dewan Consultants. The representative invited him to an informational meeting at a hotel in Dubai. 519. At the meeting, Dewan told Tharakan that those who were hired would work for a large U.S. company. They would receive a green card after working for eighteen months. At that point, they would be able to bring their families to the United States. 520. In or about June 2006, Dewan and a Signal employee interviewed Tharakan and administered a written test. After being notified that he had passed the test, Tharakan again met with Dewan. Dewan told him that he would travel to the United States on an H-2B visa, which
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would be extended until his green card had been processed. Dewan said that Signal would take care of the immigration paperwork.
521. During this meeting and later meetings in or about June and July 2006, Dewan and his employees told Tharakan that he must pay 700,000 rupees (approximately $15,344) to Dewan, Pol, and Burnett for visa and green card processing.
522. Tharakan raised the money to pay the fees by selling his and his wife’s wedding rings. He used the remainder of his wife’s jewelry as collateral for a loan at 13 percent interest, and took out another loan at 21 percent interest. Tharakan also used money that he had previously borrowed to buy property in India. Tharakan paid the first three installments of his fees in or about June and July 2006.
523. In or about September 2006, Tharakan took emergency leave from his job in Dubai to attend his H-2B visa interview at the United States Consulate in India. Because Tharakan had to wait almost two months for an interview date, his employer fired him.
524. On the day of his flight to the United States, Tharakan traveled to Dewan’s office, where he paid his final installment. Dewan refused to give Tharakan his passport and ticket until he had paid his fees, given Dewan his receipts, and signed two or three blank pieces of paper.
525. Upon arrival in the United States, Tharakan was shocked by the living conditions at Signal’s Mississippi facility. He was also surprised to learn that Signal would deduct $35 per day from his paycheck, even if he chose to live outside of the man camp. Nonetheless, Tharakan did not feel that he could complain or leave his job due to his debt, Signal’s threats of deportation, and his fears that Dewan might hurt his family. In or about March 2007, a Dewan Consultants employee called Tharakan’s family and told them that if Tharakan created any problems at Signal, his family would encounter problems in India.
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526. Moreover, in or about March 2007, Signal officials and Burnett told the workers during a camp meeting that Signal would extend their visas and file their green card applications. Tharakan believed these promises and wanted to remain in the company’s good favor so he would receive his green card.
527. Tharakan relied upon Defendants’ promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants’ “recruitment fees,” his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would institute adverse immigration action against him, Tharakan felt intimidated into acquiescence and compelled to continue working for Signal.
Kittayi Sunil Kumar Therattil 528. In or about July of 2006, Therattil saw a newspaper advertisement that offered the opportunity to work in the United States and obtain a green card. 529. The next day, Therattil traveled to the Dewan Consultants address listed on the advertisement. He met with Salimon, Dewan, and two Signal representatives. Salimon told Therattil that he would get a good job at Signal and could bring his family to the United States after approximately eight months. The Signal employees asked Therattil about his work experiences and administered a written test, which they told Therattil that he had passed. The Signal employees also told Therattil to speak with Dewan and Salimon to learn more about the details, including the cost, of the opportunity to travel to the United States. 530. Dewan and Salimon told Therattil that he would travel to the United States on an H-2B visa and would receive a green card after nine to twelve months, at which point he could bring his family to the United States. Dewan and Salimon also asked Therattil to fill out 117

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paperwork with information about his family. They told Therattil that Signal would need this information to process his family’s immigration paperwork. Therattil only agreed to pursue the opportunity at Signal because Dewan and Salimon promised him that he could bring his family to the United States.
531. Dewan told Therattil that this opportunity would cost 600,000 rupees (approximately $13,650), which Therattil paid in installments to Dewan, Pol, and Burnett. Therattil also paid additional visa and medical fees. To obtain this money, Therattil used his wife’s wedding jewelry as collateral to obtain a loan at a 9.5 percent annual interest rate. He also obtained additional loans with monthly interest rates of approximately 1.75 percent by using both his and his father-in-law’s houses and land as collateral. The 1.75 percent monthly interest rate would double if Therattil missed one payment.
532. In or about August of 2006, Therattil traveled to Dewan’s office to make payments to Pol and Burnett. Dewan assured Therattil that he would be able to live comfortably in America and that everything would proceed as Dewan had promised.
533. The next day, Therattil attended a large meeting, which was run by Dewan, Salimon, and an American. Dewan explained that Therattil and other workers should tell the U.S. consulate that they were traveling to the United States on temporary H-2B visas and would return to India after six to nine months. Dewan assured Therattil and the other workers this was part of the process, and they had nothing to worry about.
534. In or about December of 2006, Therattil traveled to Dewan Consultants’ office in Mumbai to make his final payment to Dewan. Just before Therattil left for the airport, Dewan demanded that he sign documents written in English. Therattil did not know what was written in the papers because he could not read English well, and Dewan refused to read the papers to
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Therattil. Dewan’s staff demanded that Therattil sign the papers quickly, so he signed them. Only after Therattil made his final payment to Dewan and signed the papers did Dewan give Therattil his passport.
535. After his arrival in the United States, Therattil felt compelled to remain at Signal because of the substantial debt he had incurred. Signal employees told him that if he left the company, he could not return to Signal or to the United States. Therattil feared that if he left Signal or did not complete his work perfectly, he would be deported and would be unable to repay his debt.
536. Therattil also felt compelled to remain at the man camp so that he could receive the green card that he had been promised. In particular, during a meeting shortly after Therattil arrived at Signal, he told Signal employees about the substantial amount of money he had paid and asked when he would receive his green card. Burnett, who was present at the meeting, told Therattil and other workers that they should wait, and Signal would take care of their immigration paperwork.
537. Therattil later spoke with other Signal officials about the money he had paid to work for Signal. Signal officials repeatedly assured Therattil that they would renew his H-2B visa, and a Signal employee told him that if he worked hard, Signal would take care of his green card and permanent residency.
538. In or about early 2007, Dewan traveled to the man camp. Therattil and other workers asked Dewan about their permanent residency status. They also requested refunds because of the deplorable conditions at Signal. Dewan told them to continue working.
539. Signal deducted $35 each day from Therattil’s wages for room and board.
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540. Therattil relied upon Defendants’ promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants’ “recruitment fees,” his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would institute adverse immigration action against him, Therattil felt intimidated into acquiescence and compelled to continue working for Signal.
Moni Panikulangara Thomas 541. In or about May of 2006, Thomas saw a newspaper advertisement posted by Dewan Consultants, offering welders and fitters jobs for in the United States, H-2B visas, and green cards. 542. In or about May 2006, Thomas attended a meeting where Dewan, Salimon, and an American introduced as Signal’s attorney were present. At this meeting, Dewan explained that Signal needed workers to repair oil rigs. Signal was offering workers an H-2B visa and a green card, as well as accommodations, transportation, a salary of $18 dollars per hour, and benefits. Salimon told the attendees that they must pass a practical skills test, which would cost 2,500 rupees (approximately $554). Thomas did not want to pay the money for the skills test, so he left the meeting. 543. Approximately three days after the meeting, Salimon called Thomas and encouraged him to take the skills test, telling him that he would not need to pay a fee for the test. Thomas traveled to Cochin to take the skills test, which he passed. Salimon, Dewan, and two Signal employees were present. Dewan stated that the green card program was based upon the workers obtaining an H-2B visa. Thomas told Dewan that he only wanted a green card, but Dewan replied that green cards were only available to those who accepted the H-2B option first. 120

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544. Dewan also informed Thomas that it would cost 200,000 rupees (approximately $4,430) in fees to obtain the H-2B visa, and an additional 400,000 rupees (approximately $8,860) in fees to obtain the green card. Thomas paid the combined 600,000 rupees to Defendants in installments. To obtain this money, Thomas depleted his life savings, including money he and his wife had earned working abroad that he had planned to use to build a house for his family. He also borrowed money from his brother.
545. In or about July 2006, Salimon called Thomas and told him to travel to a hotel in Cochin on August 5, 2006 to pay the first installment. On approximately August 5, 2006, Thomas traveled to the Trident Hotel in Cochin, where Dewan, Salimon, and Burnett were present. Thomas made payments to Defendants. He also filled out immigration forms, which Dewan said would be used for processing applications for his H-2B visa and green card.
546. Around the beginning of November 2006, Thomas met with Salimon, Burnett, and Dewan at a hotel in Chennai to prepare for his interview at the U.S. consulate. Dewan told Thomas that he would be interviewed about his H-2B visa application. Dewan instructed Thomas to tell the interviewer that he would return to India before the visa expired. Nonetheless, Dewan reassured Thomas that the H-2B visa would convert into a green card. Salimon, Burnett, and Dewan also asked Thomas to sign additional paperwork.
547. A few days after meeting with Salimon, Burnett, and Dewan, Thomas returned to Chennai for his interview with the consulate. Thomas met with Dewan and Salimon before the interview, and Dewan reminded Thomas that, during the interview, he should say that he planned to return to India when the visa expired.
548. A few weeks after the consulate interview, Salimon called Thomas to remind him to pay his outstanding payments. After this conversation, Thomas called Dewan several times to
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ask about his passport; Dewan responded that Thomas would receive his passport once he arrived in Mumbai and made his final payment.
549. On or about November 23, 2006, Thomas traveled to Dewan’s office in Mumbai to make his final payment and collect his passport. Thomas expressed concern to Dewan and told him that he needed the green card to be processed quickly. Dewan told Thomas to be brave and that there would be no trouble. Before giving Thomas his passport, Dewan demanded that Thomas sign various documents that were written in English, without offering him enough time to review them. Thomas felt compelled to sign the documents so that he would receive his passport.
550. After arriving in the United States, Thomas requested several times to change his living accommodations. Signal officials told him that Signal would continue to deduct the cost of room and board from his paycheck even if he lived elsewhere. Thomas felt he had no option but to continue to live at Signal’s camp because he could not afford to repay his debts in India if he paid Signal’s room and board fees in addition to paying rent to live outside the camp.
551. While working at Signal, Thomas began to feel ill, and eventually traveled to a clinic in Dorchester, Mississippi. At the clinic, the attending doctor took an echocardiogram, which revealed that Thomas’s heart was enlarged. Thomas then saw a cardiologist. Two to three days after seeing the cardiologist, Thomas had severe burning in his chest, pain in his left arm, and a high fever. A doctor diagnosed Thomas with acute pericarditis (bacterial infection of the heart). Due to this sickness, Thomas was unable to work at Signal for over one month and did not receive a salary during that time. Upon returning to work, Signal cut Thomas’s entire salary to compensate for the lost room and board payments for the entire time Thomas was unable to work, until that amount was fully paid.
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552. In approximately May 2007, Thomas still had severe chest pain and was taking medications. Worried that he was not receiving adequate treatment in the United States, Thomas asked Signal if he could travel to India for treatment. He was reluctant to put his job in jeopardy, but Signal gave him permission, specifying that Thomas could keep his job if he returned by a certain date. After receiving treatment in India, Thomas returned to Signal. He felt he had no choice but to return to Signal because he needed to repay his debts. In addition, Signal continued to promise that he would receive visa extensions, a green card, and the opportunity to settle permanently in the United States with his family.
553. Thomas relied upon Defendants’ promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants’ “recruitment fees,” his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would take adverse immigration action against him, Thomas felt intimidated into acquiescence and compelled to continue to work for Signal.
Thenooran Kumaran Unnikrishnan 554. In or about June of 2006, Unnikrishnan was working in Dubai when he saw a newspaper advertisement promising the opportunity to work in the United States and to obtain a green card. Unnikrishnan called the phone number listed on the advertisement and spoke with Dewan’s receptionist, who instructed Unnikrishnan to attend a meeting in Dubai. 555. At the meeting, Unnikrishnan was interviewed by a Signal employee. Unnikrishnan later completed and passed a skills test. A Dewan Consultants employee then told Unnikrishnan that he must pay Dewan approximately 25,000 rupees (approximately $550). Unnikrishnan borrowed money from co-workers in order to pay this fee. Before paying the fee, 123

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Unnikrishnan asked a Dewan Consultants receptionist and another employee whether he would receive a refund if his visa application for travel to the United States was unsuccessful. They told Unnikrishnan that Dewan Consultants would keep 500 dirhams (the currency of the United Arab Emirates, approximately $135, or 6,250 rupees), but would return the remainder to Unnikrishnan. Unnikrishnan then paid the fee.
556. After Unnikrishnan paid the fee, Burnett refused to meet with Unnikrishnan had paid him an additional installment of the “recruitment fees.”
557. On or about August 22, 2006, Unnikrishnan met with Burnett, Dewan, and Dewan’s brother in Dubai. Dewan told Unnikrishnan and that he would travel to the United States on an H-2B visa and that Signal would process his green card once he was in the United States. He would then receive permanent residency.
558. While Unnikrishnan was in Dewan’s office, he learned that a fax arrived stating that 250 H-2B visas had been approved. Dewan told Unnikrishnan that the first people to pay would be able to travel to the United States on one of those visas.
559. At that meeting, Unnikrishnan signed three agreements with Burnett, Pol, and Dewan. The agreements stated that Unnikrishnan would receive a green card and that this process would cost 700,000 rupees (approximately $15,400).
560. Unnikrishnan paid this amount in installments to Dewan, Burnett, and Pol. To raise the money, Unnikrishnan mortgaged his home at approximately 11 percent monthly interest and took out a second mortgage at approximately 2.6 percent monthly interest. Unnikrishnan also borrowed money from his uncle, who obtained the money by mortgaging his own home at approximately 1 percent monthly interest.
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561. On or about October 4, 2006, Unnikrishnan quit his job in Dubai and traveled to India to meet with Burnett, Dewan, and Salimon in preparation for his interview at the U.S. consulate. At the meeting, Burnett told Unnikrishnan that he should not tell anyone that he had been promised a green card. Because Unnikrishnan had already paid over 200,000 rupees (approximately $4,400), he felt that he had no choice but to comply with Burnett’s instructions. After his consular interview, Salimon told Unnikrishnan that he would not receive his passport until he paid all of his “recruitment fees.”
562. On or about November 28, 2006, the day he was scheduled to fly to the United States, Unnikrishnan traveled to the Dewan’s office in Mumbai to pay his final fee installment and obtain his passport. At the office, he saw Dewan shouting at other recruits, telling them that he would not to give them their passports if they did not pay. This frightened Unnikrishnan.
563. When Unnikrishnan met with Dewan, Dewan demanded that Unnikrishnan quickly sign paperwork written in English. Unnikrishnan did not have enough time to read it, but Dewan told him that the paperwork was for green card processing. Unnikrishnan felt compelled to sign the paperwork quickly, give Dewan all the documents that he demanded, and pay Dewan so he would not miss his flight.
564. Before Unnikrishnan left Dewan’s office, Dewan informed him for the first time that Signal would deduct approximately $35 per day for room and board. Dewan also told him that he would travel to the United States on an H-2B visa, and Signal would not process his green card until eight months after Unnikrishnan arrived in the United States. Unnikrishnan was devastated, but felt he had no choice but to continue to the United States because Dewan, for the first time, told Unnikrishnan that he could not receive a refund for the fees he had paid.
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565. Upon arriving in Mississippi, Unnikrishnan filled out and signed several documents. He did not know what he was signing because the Signal employees told him to sign the documents immediately. During his first week, Unnikrishnan also attended meetings at which Signal employees stated that Signal would apply for the workers’ green cards, but that if the workers did not follow Signal’s rules, they would be terminated without warning. In addition, in or about February of 2007, Signal posted a notice stating that Unnikrishnan and other workers should submit copies of their immigration forms and passports to John Sanders for green card processing. Even after the incident in March 2007 when a number of workers were deported, John Sanders again assured Unnikrishnan that his green card would be processed easily, and Dewan told him that Signal would arrange everything for him. Unnikrishnan remained at Signal due to his heavy debts and Signal’s repeated promises that he would receive a green card. In or about July of 2007, Malvern Burnett told Unnikrishnan that his visa extension was being processed and would soon be granted.
566. Unnikrishnan relied upon Defendants’ promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants’ “recruitment fees,” his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would institute adverse immigration action against him, Unnikrishnan felt intimidated into acquiescence and compelled to continue working for Signal.
Benny Chittilappilly Vareed 567. In or about May of 2006, Vareed saw a newspaper advertisement placed by Dewan Consultants. The advertisement offered the opportunity to work in the United States as a welder or fitter and to obtain a green card. 126

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568. In or about mid-May of 2006, Vareed attended a meeting led by Dewan, Burnett, and Salimon. Burnett explained that Vareed could travel to the United States on an H-2B visa and work for Signal. The H-2B visa would later be converted to a green card.
569. Dewan explained that this process would cost 800,000 rupees (approximately $17,720); Vareed’s H-2B visa would cost 300,000 rupees (approximately $6645) and his green card would cost 500,000 rupees (approximately $11,075). However, Salimon later called Vareed and said that he could pay a total of 600,000 rupees (approximately $13,290). Vareed paid this amount in installments to Defendants. To obtain the money for his “recruitment fees,” Vareed borrowed money from his wife’s family and sold his wife’s wedding jewelry.
570. Vareed also took a welding test, which he passed. The test was administered by Dewan, Salimon, and two or three Signal employees.
571. In or about August of 2006, Vareed met with Dewan, Salimon, and Burnett at a hotel in India, where Vareed made a payment to Defendants. Dewan, Salimon, and Burnett required Vareed to sign several forms written in English, which Vareed could not read well. Vareed signed and completed forms based on Salimon’s instructions.
572. In or about the fall of 2006, Vareed met with Dewan, Salimon, and Burnett to prepare for his interview with the U.S. consulate. Dewan told Vareed that he should not inform the consulate that he would receive a green card and, if he did so, Vareed’s visa would not be approved. Vareed felt compelled to follow Dewan’s instructions because he had already incurred significant debt to pay Defendants.
573. On or about November 19, 2006, Vareed traveled to Mumbai to make his final payment to Dewan and retrieve his passport. Dewan’s brother and other Dewan Consultants employees immediately demanded that Vareed sign paperwork written in English. Vareed did
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not know what the paperwork said, but felt compelled to sign because he had to leave for the airport almost immediately. Vareed also made his final payment to Dewan. Only after Vareed made this payment did Dewan give him his passport. Vareed then hurried to the airport and flew to the United States.
574. Upon arrival in the United States, Signal reduced Vareed’s wages from $19 to $17.50 per hour. Vareed pleaded with his foreman for Signal to increase his wages. The foreman agreed to increase Vareed’s wages if he worked hard. Because he had incurred substantial debt to travel to the United States, Vareed felt compelled to agree to the wage reduction.
575. Signal also deducted $35 per day from Vareed’s paycheck for room and board. Vareed asked John Sanders if he could live outside the man camp, but Sanders informed him that Signal would deduct this room and board fee even if Vareed lived elsewhere. Vareed felt financially compelled to remain at the man camp to repay his debt. Vareed also felt compelled to endure the deplorable conditions at Signal because his H-2B visa did not allow him to work for any other employer in the United States.
576. Vareed attended several meetings led by Signal officials. At many meetings, Vareed and other employees informed Signal officials that they had incurred substantial debt to work for Signal. They also asked about the status of their green cards. In response, John Sanders informed Vareed and other workers that Signal would only give green cards to workers who did good work according to Signal’s standards. Vareed felt that he had no choice but to obey all of Signal’s demands if he wanted to obtain the green card he had been promised.
577. After the March 9, 2007 incident discussed above, Vareed feared that, if he complained, Signal would retaliate against him and arrange for his deportation. Vareed knew
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that if he were deported, he would then be unable to repay his debt. Consequently, Vareed felt that he could not voice his concerns about the conditions at the man camp.
578. Shortly thereafter, Vareed attended a meeting at the man camp led by Dewan and Burnett. Both Dewan and Burnett promised Vareed and other employees that their green card processing would continue as promised. In or about July of 2007, a Signal manager and Darrell Snyder assured Vareed and other Signal employees that their visa would be extended. Based on these promises, Vareed continued to work at Signal.
579. In or about May of 2007, Vareed returned to India after his young son became seriously ill. He was reluctant to put his job in jeopardy, but Signal gave him permission, specifying that Thomas could keep his job if he returned by a certain date. After just 14 days, Vareed returned to Signal. He felt he had no choice but to return to Signal because he needed to repay his debts. In addition, Signal had continued to promise that he would receive visa extensions and a green card.
580. Vareed relied upon Defendants’ promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants’ “recruitment fees,” his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would institute adverse immigration action against him, Vareed felt intimidated into acquiescence and compelled to continue working for Signal.
George Pulikkeparambil Varghese 581. In or about November and December 2003, Varghese’s sister-in-law’s father told Varghese’s son about an opportunity to work in the United States as a welder. Varghese’s sister-
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in-law told Varghese’s son that there would be a meeting to learn more about the opportunity. Varghese’s son attended the meeting.
582. Soon thereafter, Varghese met with Dewan and Salimon. Dewan told Varghese that his son could work in America as a welder. He explained that this process would cost at least 500,000 rupees (approximately $10,700).
583. Varghese and his son paid these fees to Dewan, Pol, and Burnett. To make these payments, Varghese sold some gold jewelry owned by the family. He also mortgaged his home to borrow a large amount of money from a bank at an interest rate of approximately 17.9 percent. Varghese and his son made their final payments to Dewan and Salimon in or about August 2004.
584. For approximately two years after he made his final payment, Varghese’s son remained in India but heard nothing from Defendants. Varghese’s son repeatedly called Salimon, who assured him that he would be able to go to the United States soon.
585. In or about June 2006, Varghese and his son learned from friends that Dewan Consultants was still interviewing people. Then in or about August 2006, Varghese saw a newspaper advertisement in which Dewan Consultants offered opportunities for pipefitters and welders to work in the United States. Varghese’s son called Dewan Consultants and spoke with Salimon. Salimon explained that Dewan Consultants was conducting interviews for people to work for Signal and travel to the United States on an H-2B visa. Salimon said that Varghese and his son should attend a meeting on or about September 8, 2006.
586. At this meeting, Dewan and Salimon explained that they were looking for people to travel to the United States on H-2B visas, which would be extended while their green cards were processed. Varghese’s son decided to travel to the United States and work at Signal, but he
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failed his visa interview and could not go. Salimon told Varghese that Varghese could work at Signal instead.
587. Varghese completed his interview process and gave Dewan Consultants his passport for visa processing. Salimon then told Varghese that he would have to pay an additional 278,000 rupees (approximately $6,308) in cash within one day. Varghese paid this fee. In order to raise the money, he borrowed some money from his brother and sisters, and used his savings to finance the remainder.
588. On the day of his flight to the United States, Varghese traveled to Dewan’s office in Mumbai. A large number of people were waiting in Dewan’s office, and Varghese had to wait almost the entire day before anyone at the office met with him. When Dewan’s brother finally met with Varghese, he told Varghese that he had to sign a document written in English before he could receive his plane ticket. Because Varghese needed to leave for the airport immediately, he did not have enough time to read the document. He signed quickly and left the office.
589. After he arrived at Signal, Varghese worked for approximately two weeks. Signal employees then told him that there was not enough work for him, and they would let him know when he could work again. Varghese did not work for two weeks. Then, Darrell Snyder told him that he could work, but only for $9 per hour. Snyder said that if Varghese refused, he would have to go back to India. Afraid of being sent back to India, where he would not be able to repay his debts, Varghese felt that he had no choice but to work for the lower wage.
590. Varghese relied upon Defendants’ promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants’
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“recruitment fees,” his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would institute adverse immigration action against him, Varghese felt intimidated into acquiescence and compelled to continue working for Signal.
Estate of Kuliyanickal Paily Varghese 591. In or about early June of 2006, K. Varghese saw a newspaper advertisement posted by Dewan Consultants. The advertisement offered the opportunity to work as a welder and obtain permanent residency in the United States. The advertisement specified that applicants should take a welding test in late June of 2006. 592. On the day of the test, K. Varghese traveled to the testing facility in Kochi. Before K. Varghese took the test, Dewan and Salimon explained that the cost of employment and obtaining a green card would be 700,000 rupees (approximately $15,217). Dewan also explained that applicants who passed the welding test would travel to the United States on H-2B visas, but their green card applications would be processed within six months, and they would then be able to bring their families to the United States. A Signal employee administered K. Varghese’s welding test and told him that he had passed. 593. Approximately one week after the test, K. Varghese traveled to Salimon’s office in Kerala to pay his first installment. He also signed several forms, which he believed were related to his visa and permanent residency application. 594. Approximately two weeks after he visited Salimon’s office, K. Varghese received a letter from Dewan that explained that K. Varghese would pay Burnett, Pol, Dewan, and Salimon in installments. The letter also explained that K. Varghese’s payments would go towards his employment and permanent residency in the United States. To obtain the 700,000 rupees that he paid Defendants, K. Varghese sold his wife’s gold and jewelry. He also took out a loan for 550,000 rupees (approximately $11,957) at a 13.5 percent interest rate. 132

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595. About two weeks after receiving this letter, K. Varghese traveled to Salimon’s office to make a payment to Defendants. Dewan, Salimon, and Burnett were present. Salimon explained that Burnett would process K. Varghese’s paperwork. Salimon also promised K. Varghese that he would receive employment and a green card in the United States. Dewan, Salimon, and Burnett made similar promises throughout K. Varghese’s application process.
596. In or about October of 2006, K. Varghese traveled to Chennai to meet with Salimon, Dewan, and Burnett and to prepare for his interview with the U.S. consulate. Salimon told K. Varghese that he should tell the consulate that he only intended to stay in the United States temporarily. Burnett, Dewan, and Salimon nonetheless emphasized that even though K. Varghese was seeking an H-2B visa from the consulate, he would receive a green card approximately one year after arriving in the United States, and his family would also obtain permanent residency. Based on these assurances, K. Varghese continued with the application process.
597. On or about November 27, 2006, K. Varghese traveled to Dewan’s office to make his final payment and retrieve his passport. Dewan demanded that K. Varghese quickly sign paperwork without reading it. Dewan also demanded that K. Varghese return all of his receipts and the letters that Dewan had sent him. K. Varghese felt compelled to comply because he had already paid Dewan so much money and did not want Dewan to prevent him from traveling to the United States. Only after K. Varghese returned the paperwork and paid Dewan did Dewan give K. Varghese his plane ticket and passport. K. Varghese then immediately left for the airport, where he boarded his flight to the United States.
598. Upon arrival in the United States, K. Varghese learned that Signal would deduct $245 from each of his paychecks for room and board. K. Varghese told Signal officials that he
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wanted to live outside the man camp, but they forbade him from doing so. Afterward, workers told K. Varghese that even though he could leave, Signal would continue to deduct $245 each week. Because Signal would charge him for room and board regardless of where he lived, K. Varghese felt that he had no option but to remain at the man camp.
599. While at Signal, K. Varghese attended several meetings in which Burnett and Signal employees assured him that they would seek visa extensions for him. K. Varghese remained at Signal so that he could receive the green card he had been promised and repay his substantial debts.
600. Signal officials also repeatedly threatened to have K. Varghese deported if he did not obey all of Signal’s rules. Therefore, he felt compelled to remain at the man camp, fearing that Signal would have him deported if he left.
601. K. Varghese relied upon Defendants’ promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants’ “recruitment fees,” his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would institute adverse immigration action against him, K. Varghese felt intimidated into acquiescence and compelled to continue working for Signal.
602. On or about November 26, 2012, K. Varghese died in a car accident. K. Varghese’s claims against Defendants survive his death and are brought on behalf of his estate.
Benny Kattukariyil Varkey 603. In or about February 2006, Varkey’s co-worker told him about an opportunity from Dewan Consultants to work as a welder in the United States and obtain a green card.
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Varkey called Dewan Consultants and spoke with Salimon, who told him to attend a seminar in April or May.
604. In or about March 2006, Varkey called Dewan Consultants again and spoke with Salimon, who invited him to come to his office. Salimon explained that Varkey would travel to the United States on an H-2B visa that would later become a green card. He said that the total cost would be 800,000 rupees (approximately $18,080). Salimon told Varkey to look for an advertisement giving the details about a meeting at the Hilton Hotel. That same day, Varkey saw the advertisement for the meeting. This advertisement also offered the opportunity to obtain an H-2B visa and a green card.
605. At the seminar, Salimon, Dewan, and an American whom Dewan explained was a lawyer for Signal gave a presentation about the jobs at Signal. Dewan promised the workers that they would receive green cards. Similarly, the American lawyer assured them that they would travel to the United States on H-2B visas that would become green cards after nine months. After the presentation, Dewan reiterated that the cost for the green card would be 800,000 rupees (approximately $18,080). These fees would be paid to Dewan, Pol, and Burnett.
606. In or about June 2006, Varkey took a skills test administered by a Signal employee. Salimon and Dewan were also present. The Signal representative informed Varkey that he passed. Varkey began to raise the money to pay the Agents their “recruitment fees.”
607. To raise the money to pay the fees, Varkey depleted the savings that had set aside to buy a house for his family. Varkey also borrowed money from his brother and used his wife’s gold jewelry as collateral to obtain a second loan. Varkey’s wife had received this jewelry as a wedding gift from her parents, who had spent their life savings to purchase it. Varkey and his brother mortgaged their properties to obtain additional loans.
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608. Varkey paid his first payment at Dewan’s office in or about June 2006. Salimon told Varkey to sign papers written in English, which he did not fully understand. He told Varkey that the papers were for his green card processing.
609. In or about August 2006, Varkey paid his second fee installment. Shortly after he made this payment, Salimon called to tell him that the fees had been reduced to 600,000 rupees (approximately $12,960).
610. Just before Varkey left for the United States, Varkey traveled to Dewan’s office in Mumbai, where he paid his final installment. Dewan told Varkey that $3 per hour would be deducted from his paycheck for room and board. Dewan also informed Varkey that his H-2B visa would have to be extended for an additional nine months before the green card processing could begin. He said that when Varkey’s green card had been processed, he would return to India, after which he could go back to the United States with his family.
611. Dewan’s staff also required Varkey to sign English-language documents and return all documents relating to the green card opportunity he had been promised. They refused to explain to Varkey what he was signing. The office was crowded, Varkey felt rushed, and he knew that he would not receive a refund if he refused to sign. Only after Varkey had paid his final fee installment, signed the English-language documents, and given Dewan the documents relating to green cards did he receive his passport.
612. When Varkey arrived at Signal, he signed a number of English-language documents that he did not understand. He later learned that Signal would deduct $35 per day from his paycheck even if he lived outside of the camp. Varkey felt that he had no choice but to live at the camp because he could not afford to repay his debts if he paid rent on top of his room
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and board payment to Signal. In addition, Varkey was afraid to leave his job because of his substantial debts. He knew that if he returned to India, he would not be able to repay the loans.
613. Varkey also believed that if he left Signal, he would not receive the green card that Signal and its Agents continued to promise him. In or about late 2006 or early 2007, John Sanders told Varkey that the green card process was moving forward. During the same time period, Varkey also attended a camp meeting at which Burnett said that Signal would process the workers’ green cards.
614. Varkey relied upon Defendants’ promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants’ “recruitment fees,” his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would institute adverse immigration action against him, Varkey felt intimidated into acquiescence and compelled to continue working for Signal.
Shahi Vijayan 615. In or about March or April 2006, Vijayan saw a newspaper advertisement placed by Dewan Consultants offering the opportunity to obtain permanent residency in the United States. Vijayan called Dewan Consultants, and an employee invited him to an informational meeting. 616. Dewan, Salimon, Burnett, and two Signal representatives attended the meeting. Dewan explained that if workers waited for their green cards before traveling to the United States, they would have to wait eighteen months. However, if they traveled to the United States on H-2B visas, they could leave in six months. Their green cards would be processed between three to six months after the workers arrived in the United States. Dewan explained that Signal 137

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would be responsible for this process. He said that the total cost would be 800,000 rupees (approximately $18,280).
617. Signal’s representatives provided the company’s website address at the meeting. Vijayan reviewed the website and felt that Signal looked reputable.
618. At this time, Vijayan also had an opportunity to work in Australia. He mentioned this to Dewan, who assured him that working for Signal would guarantee Vijayan’s permanent residency and allow him to bring his family to the United States. Salimon also assured Vijayan that Signal was an excellent company. Based on Dewan’s and Salimon’s assurances, Vijayan refused the job in Australia.
619. Vijayan paid the fees demanded in approximately four installments. In order to raise the money, he mortgaged his house and land at 12.5 percent interest. He also sold his wife’s gold jewelry and used her wedding necklace as collateral to obtain another loan at 12.5 percent interest. Vijayan borrowed the remainder of the money from private lenders who charged high interest rates.
620. In or about August 2006, Vijayan met with Burnett and made payments to Burnett and Pol. At that meeting, Burnett guaranteed Vijayan that he would receive a green card if he worked for Signal.
621. Just before Vijayan’s flight to America, he traveled to Dewan’s office in Mumbai. Dewan’s employees required him to sign some documents in English, which Vijayan did not speak well. Vijayan did not fully understand the documents. Dewan’s employees nonetheless rushed Vijayan and refused to give him his passport until he paid his final installment fees and signed the documents. Vijayan felt intimidated. He saw people crying because they did not have
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enough money to make their final payment and Dewan had refused to give them their passports. Vijayan signed the paperwork.
622. When Vijayan arrived in the United States, Signal also required Vijayan to sign English-language documents that he did not understand.
623. Upon arrival in Pascagoula, Vijayan learned for the first time that the company would deduct $35 from his paycheck each day for room and board, even if he chose not to live at the man camp. Vijayan felt compelled to live and work at Signal because he was afraid of being sent back to India, where he would be unable to repay his debts. Vijayan also stayed because Signal personnel convinced him during conversations that he could receive a green card if he remained.
624. Vijayan relied upon Defendants’ promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants’ “recruitment fees,” his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would institute adverse immigration action against him, Vijayan felt intimidated into acquiescence and compelled to continue working for Signal.
John Yohannan 625. In or about May 2006, Yohannan saw a newspaper advertisement that Dewan Consultants had placed, offering the opportunity to work in the United States and obtain a green card. Yohannan called Dewan Consultants’ local office and scheduled a meeting. 626. At that meeting, Yohannan met with Salimon, who told Yohannan that he could work for Signal, obtain a green card after working for one year, and earn a good salary. Salimon also told Yohannan that Signal was a reputable company. 139

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627. Shortly after that meeting, Yohannan took and passed a welding test administered by Michael Pol and a Signal employee. Pol and the Signal employee told Yohannan to contact Salimon’s office. When Yohannan contacted the office, Salimon repeated his earlier promise that Yohannan would receive a green card.
628. Yohannan later attended a larger meeting, where Pol, Salimon, and Dewan again stated that Signal was a reputable American company and that Yohannan and other workers could obtain a green card and U.S. citizenship. They told Yohannan that he would earn $18 per hour at Signal and receive food and housing. Pol, Salimon, and Dewan did not mention H-2B visas or any paycheck deductions.
629. In or about August 2006, Yohannan met with Pol, Burnett, Dewan, and Salimon before his interview with the U.S. consulate. They emphasized that if the consulate asked Yohannan anything about the fees he had paid for his recruitment, he should say that he paid nothing.
630. Yohannan ultimately paid Dewan, Pol, and Burnett approximately 1,150,000 rupees (approximately $25,000) for this opportunity. To pay for these fees, Yohannan used his savings and took out loans at a 12 percent interest rate. He secured some of these loans by pledging his wife’s jewelry as collateral.
631. Before he left India, Yohannan also had an opportunity to work as a welder in Saudi Arabia. Based on Defendants’ promises, he gave up that opportunity and instead traveled to the United States to work for Signal.
632. Just before Yohannan flew to the United States, he met with Dewan in his Mumbai office. Dewan refused to give Yohannan his passport and airline ticket until Yohannan paid the remaining balance of his fees. Dewan demanded that Yohannan quickly sign various
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documents, but he rushed Yohannan and did not give him enough time to read them. Feeling rushed and anxious to get to the airport in time for his flight, Yohannan signed the documents.
633. In the United States, Yohannan learned that Signal would deduct approximately $260 each week from his paycheck for room and board.
634. Yohannan and other Indian workers attended meetings where they asked Sanders and other Signal employees when they would receive their green cards. The Signal employees told them that Signal would apply for their green cards at the appropriate time.
635. Yohannan relied upon Defendants’ promises of permanent residency and good working conditions and would not have sold assets, incurred substantial debt, or agreed to work for Signal in the absence of such falsehoods. Based on his fear of mistreatment and abuse by Signal, his need to repay the substantial debt and interest he had incurred to pay Defendants’ “recruitment fees,” his fear that Signal would confiscate even more of his hard-earned wages, and his fear that Signal or Burnett would institute adverse immigration action against him, Yohannan felt intimidated into acquiescence and compelled to continue working for Signal.
FIRST CLAIM FOR RELIEF THE TRAFFICKING VICTIMS PROTECTION REAUTHORIZATION ACT (“TVPRA”) OF
2003 AGAINST ALL DEFENDANTS Forced Labor (18 U.S.C. § 1589) and Trafficking with Respect to Peonage, Slavery, Involuntary
Servitude, or Forced Labor (18 U.S.C. § 1590) 636. Each Plaintiff re-alleges and incorporates by reference each and every allegation contained in the preceding paragraphs as if fully set forth herein. 637. Each Plaintiff brings this claim against all Defendants. 638. Each Plaintiff is authorized to bring these civil claims against all Defendants pursuant to the civil remedies provisions of 18 U.S.C. § 1595.
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639. Defendants Signal, Dewan, Burnett, and Pol attempted to and did subject each Plaintiff to forced labor in violation of 18 U.S.C. § 1589.
640. Defendant Signal employed Plaintiffs in dangerous conditions at a guarded and gated man camp, and all Defendants falsely assured Plaintiffs that if they continued to work, Signal would assist them in applying for and receiving green cards. Defendants controlled Plaintiffs’ housing, food, access to medical care, and other basic needs, and if Plaintiffs did not continue working for Signal, they would have been cut off from those needs.
641. Furthermore, the substantial “recruitment fees” that Defendants coerced Plaintiffs into paying forced Plaintiffs to work at Signal to pay off their substantial debts.
642. Defendants knowingly attempted to and did physically restrain and/or threaten each Plaintiff with serious harm in order to obtain the labor and services of each Plaintiff in violation of 18 U.S.C. §1589(1).
643. Defendants knowingly attempted to and did obtain the labor and services of each Plaintiff using a scheme, plan, or pattern which, in the totality of the circumstances, was intended to coerce and did coerce each Plaintiff to believe that he would suffer serious harm if he were to leave the employ of Defendant Signal in violation of 18 U.S.C. § 1589(2).
644. Defendants’ scheme to isolate Plaintiffs, coerce them to live in conditions causing psychological harm, and limit their outside contacts, which included unlawful discrimination in violation of 42 U.S.C. § 1981, was designed to convince Plaintiffs that they would suffer serious harm if they were to leave the employ of Signal.
645. Defendants threatened not to extend Plaintiffs’ H-2B visas, not to sponsor Plaintiffs for green cards, to deport Plaintiffs, and to send them back to India if they complained about conditions at Signal, and also deceived Plaintiffs about the terms of their immigration
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status, each in a manner that constitutes an abuse of the legal process under 18 U.S.C. § 1589(3). Defendants retaliated against Plaintiffs when they sought legal advice regarding their rights and immigration status.
646. Defendants knowingly recruited, transported, harbored, provided, and/or obtained the Plaintiffs so as to procure their labor and services in violation of laws prohibiting peonage, involuntary servitude, and forced labor within the meaning of the provisions of 18 U.S.C. § 1590.
647. In violation of 18 U.S.C. § 1590, and in addition to the violations of 18 U.S.C. § 1589 set forth above, Defendants knowingly recruited, transported, harbored and/or obtained the Plaintiffs for labor or services in furtherance of Defendants’ violations of the following provisions of Title 18, Chapter 77 of the U.S. Code:
a. enticing, persuading, or inducing the Plaintiffs to board an airliner and to travel to various locations throughout India and the United States, with the intent that they may be made or held in modern-day slavery, violating 18 U.S.C. § 1583;
b. knowingly and willfully holding Plaintiffs to involuntary servitude, as defined by the TVPRA, 22 U.S.C. §7102(5)(a) and (b), thereby violating 18 U.S.C. § 1584;
c. removing, confiscating, or possessing Plaintiffs’ and other class members’ passports and other immigration documents in the course of violating, or with the intent to violate 18 U.S.C. §§ 1583, 1584, 1589, and 1590, thereby violating 18 U.S.C. § 1592(a); and
d. attempting to violate 18 U.S.C. §§ 1583, 1584, 1589, and 1590, thereby violating 18 U.S.C. § 1594(a).
648. Defendants’ actions evince malice and/or reckless indifference towards Plaintiffs.
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649. As a proximate result of the conduct of Defendants, Plaintiffs have suffered injuries to their persons, businesses, and property, as well as other damages. Plaintiffs are entitled to recover damages for the period up to and including the time that Plaintiffs were employed by Signal. Those damages include compensatory damages (including, without limitation, loss of wages, loss of opportunity, pain and suffering, mental and emotional distress, prejudgment interest, and additional economic loss from (1) recruitment and visa fees paid to Defendants; (2) expenses that Plaintiffs incurred to pay such fees, including but not limited to interest from loans; (3) medical expenses; (4) damages related to living and working conditions; and (5) mandatory housing and other fees paid to Signal), punitive damages, and attorneys’ fees in an amount to be proven at trial.
SECOND CLAIM FOR RELIEF VIOLATIONS OF THE CIVIL RIGHTS ACT OF 1866
42 U.S.C. § 1981 BROUGHT AGAINST SIGNAL 650. Each Plaintiff re-alleges and incorporates by reference each and every allegation contained in the preceding paragraphs as if fully set forth herein. 651. Each Plaintiff asserts this claim pursuant to 42 U.S.C. § 1981 for declaratory relief and damages against Defendant Signal. 652. Each Plaintiff is a member of a racial minority, as contemplated by 42 U.S.C. § 1981. 653. The actions of Defendant Signal, as set forth herein, violated Plaintiffs’ rights to receive full and equal benefit of all laws as guaranteed by 42 U.S.C. § 1981, including Plaintiffs’ rights to enjoy and benefit from non-discriminatory employment relationships with Defendant Signal.
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654. Specifically, Defendant Signal subjected Plaintiffs to discriminatory and offensive mandatory room and board arrangements at Signal man camps in Pascagoula. Defendant Signal did not subject its employees of non-Indian race, ethnicity, or alienage to the same or similar room and board arrangements.
655. As set forth in the preceding paragraphs, Defendant Signal also imposed discriminatory job-related requirements and adverse terms and conditions of employment to which its employees of non-Indian race, ethnicity, or alienage were not similarly subject.
656. As set forth in the preceding paragraphs, Defendant Signal also created and fostered a discriminatory work environment in which Indian workers were subjected to antiIndian invectives throughout the time Plaintiffs were employed, and in which Signal forced Sikh workers to shave religiously mandated beards. Signal employees of non-Indian race, ethnicity, or alienage or not of the Sikh religion were not subjected to a similar work environment.
657. As set forth in the preceding paragraphs, through the actions and statements of its personnel referring to and/or directed at Plaintiffs and other Indian H-2B workers, Defendant Signal maintained an objectively hostile and abusive work environment on account of Plaintiffs’ race, ethnicity, religion, and alienage throughout the time Plaintiffs were employed.
658. As set forth in the preceding paragraphs, Defendant Signal's discriminatory and offensive treatment of Plaintiffs was sufficiently severe that it created a hostile work environment in violation of 42 U.S.C. § 1981 throughout the time Plaintiffs were employed.
659. Plaintiffs reasonably perceived their work environment to be hostile, abusive, and discriminatory on the basis of their race, ethnicity, religion, and alienage.
660. Defendant Signal's hostile, abusive, and discriminatory treatment of Plaintiffs and other class members was unwelcome.
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661. Defendant Signal knowingly, willfully, maliciously, intentionally, and without justification acted to deprive Plaintiffs of their rights.
662. Defendants’ actions evince malice and/or reckless indifference towards Plaintiffs. 663. As a direct and proximate result of Defendants’ knowing, willing, and intentional actions, each Plaintiff has been injured, and is entitled to recover damages for the period up to and including the time that Plaintiffs were employed by Signal. Those damages include compensatory damages (including, without limitation, loss of wages, loss of opportunity, pain and suffering, mental and emotional distress, prejudgment interest, and additional economic loss from (1) medical expenses; (2) damages related to living and working conditions; and (3) mandatory housing and other fees paid to Signal), punitive damages, and attorneys’ fees in an amount to be proven at trial.
THIRD CLAIM FOR RELIEF FRAUDULENT MISREPRESENTATION UNDER MISSISSIPPI LAW AGAINST ALL
DEFENDANTS 664. Each Plaintiff re-alleges and incorporates by reference each and every allegation contained in the preceding paragraphs as if fully set forth herein. 665. Each Plaintiff brings this claim against all Defendants. 666. The actions of Defendants, as set forth herein, constitute fraudulent misrepresentation under Mississippi common law. 667. Specifically, Defendants, individually and through their agents, employees, and/or representatives, knowingly made materially false and untrue statements and representations to Plaintiffs regarding the nature, terms, and conditions of applications and opportunities for immigration status and employment in the United States.
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668. Defendants and/or their respective agents represented to each Plaintiff that (1) Plaintiffs would be eligible for permanent residency given their employment with Signal; (2) Defendants would apply for permanent residency in the United States on behalf of Plaintiffs no later than 24 months after the commencement of work; and (3) Plaintiffs would have steady and ongoing work opportunities in the United States with Defendant Signal.
669. At the time each of these representations was made, Defendants knew they were false or misleading.
670. Defendants intended that the false statements made by each Defendant and/or the Defendants’ respective agents, employees, and/or representatives would induce Plaintiffs to pay the exorbitant “recruitment fees,” would induce Plaintiffs to leave their homes and jobs abroad, travel to the United States, and work for Signal, and would induce Plaintiffs to pay the room and board fee and other fees extracted by Signal upon the workers’ arrival in the United States.
671. Each Plaintiff was entitled to, and did, rely on Defendants’ representations. 672. In reasonable reliance on the false representations of Defendants and their respective agents, employees, and/or representatives regarding green cards, employment opportunities, and employment conditions, Plaintiffs paid large sums of money and incurred substantial debt in the guise of “recruitment fees” and other travel and immigration-related fees. Signal knew of these payments, and permitted them to be made to the Agents. 673. In reasonable reliance on the false representations of Defendants and their respective agents, employees, and/or representatives regarding green cards, employment opportunities, and employment conditions, Plaintiffs surrendered employment opportunities in India and abroad, left their homes and families behind, sold personal and real property, secured loans at usurious interest rates, traveled to the United States, and worked for Signal. Further,
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once in the United States, Plaintiffs continued to work for Signal after receiving repeated assurances that Defendants’ prior representations were in fact true.
674. No later than the first day that Indian workers arrived at Signal, Defendants knew that Plaintiffs and their coworkers believed that Defendants had applied, or were intending to apply, for permanent residency on behalf of Plaintiffs. Defendants therefore had an obligation to tell Plaintiffs that this was not true. Defendants failed to do so.
675. Defendants’ actions evince malice and/or reckless indifference towards Plaintiffs. 676. As a direct and proximate result of Defendants’ knowing, willing, and intentional actions, each Plaintiff has been injured, and is entitled to recover damages for the period up to and including the time that Plaintiffs were employed by Signal. Those damages include compensatory damages (including, without limitation, loss of wages, loss of opportunity, pain and suffering, mental and emotional distress, prejudgment interest, and additional economic loss from (1) recruitment and visa fees paid to Defendants; (2) expenses that Plaintiffs incurred to pay such fees, including but not limited to interest from loans; (3) medical expenses; (4) damages related to living and working conditions; and (5) mandatory housing and other fees paid to Signal), punitive damages, and attorneys’ fees in an amount to be proven at trial.
FOURTH CLAIM FOR RELIEF NEGLIGENT MISREPRESENTATION UNDER MISSISSIPPI LAW AGAINST ALL
DEFENDANTS 677. Each Plaintiff re-alleges and incorporates by reference each and every allegation contained in the preceding paragraphs as if fully set forth herein. 678. Each Plaintiff brings this claim against all Defendants. 679. The actions of Defendants, as set forth herein, constitute negligent misrepresentation under Mississippi common law.
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680. Specifically, Defendants, individually and through their agents, employees, and/or representatives, negligently made materially false and untrue statements and representations to Plaintiffs regarding the nature, terms, and conditions of applications and opportunities for immigration status and employment in the United States.
681. Defendants represented to each Plaintiff that (1) Plaintiffs would be eligible for permanent residency upon the conclusion of their employment with Signal; (2) Defendants would apply for permanent residency in the United States on behalf of Plaintiffs no later than 24 months after the commencement of work, (3) Plaintiffs would have steady and ongoing work opportunities in the United States with Defendant Signal.
682. At the time each of these representations was made, Defendants should have known that they were false or misleading.
683. Defendants should have known that the false statements made by each Defendant and/or the Defendants’ respective agents, employees, and/or representatives would induce Plaintiffs to pay the exorbitant “recruitment fees”; would induce Plaintiffs to leave their homes and jobs abroad, travel to the United States, and work for Signal; and would induce Plaintiffs to pay the room and board fee and other fees extracted by Signal upon the workers’ arrival in the United States.
684. Each Plaintiff was entitled to, and did, rely on Defendants’ representations. 685. In reasonable reliance on the negligent representations of the Defendants and their respective agents, employees, and/or representatives regarding green cards, employment opportunities, and employment conditions, Plaintiffs paid large sums of money and incurred substantial debt in the guise of “recruitment fees” and other travel and immigration-related fees. Signal knew of these payments, and permitted them to be made to the Agents.
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686. In reasonable reliance on the negligent representations of the Defendants and their respective agents, employees, and/or representatives regarding green cards, employment opportunities, and employment conditions, Plaintiffs surrendered employment opportunities in India and abroad, left their homes and families behind, sold personal and real property, secured loans at usurious interest rates, traveled to the United States, and worked for Signal. Further, once in the United States, Plaintiffs continued to work for Signal after receiving repeated assurances that Defendants’ prior representations were in fact true.
687. No later than the first day that Indian workers arrived at Signal, Defendants knew that Plaintiffs and their coworkers believed that Defendants had, or were intending to, apply for permanent residency on behalf of Plaintiffs. Defendants therefore had an obligation to tell Plaintiffs that this was not true. Defendants failed to do so.
688. Defendants’ actions evince malice and/or reckless indifference towards Plaintiffs. 689. As a direct and proximate result of Defendants’ negligent actions, Plaintiffs have been injured, and are entitled to recover damages for the period up to and including the time that Plaintiffs were employed by Signal. Those damages include compensatory damages (including, without limitation, loss of wages, loss of opportunity, pain and suffering, mental and emotional distress, prejudgment interest, and additional economic loss from (1) recruitment and visa fees paid to Defendants; (2) expenses that Plaintiffs incurred to pay such fees, including but not limited to interest from loans; (3) medical expenses; (4) damages related to living and working conditions; and (5) mandatory housing and other fees paid to Signal), punitive damages, and attorneys’ fees in an amount to be proven at trial.
FIFTH CLAIM FOR RELIEF BREACH OF CONTRACT UNDER MISSISSIPPI LAW AGAINST ALL DEFENDANTS
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690. Each Plaintiff re-alleges and incorporates by reference each and every allegation contained in the preceding paragraphs as if fully set forth herein.
691. Each Plaintiff brings this claim against all Defendants. 692. The actions of Defendants, as set forth herein, constitute breach of contract under Mississippi common law. 693. Specifically, Defendants, individually and through their agents, employees and/or representatives, promised to assist Plaintiffs in applying for and obtaining permanent residency and immigration status for Plaintiffs in the United States no later than 24 months after the commencement of work, and promised Plaintiffs steady and ongoing work opportunities in the United States with Defendant Signal. 694. These promises were made in exchange for each Plaintiff’s payment of fees (including recruitment, immigration application, and travel fees) to Defendants and their employees, agents, and/or representatives, and in exchange for each Plaintiff’s agreement to work for Signal. 695. Each Plaintiff accepted Defendants’ offers and promises; each Plaintiff paid the agreed upon fees, and performed the agreed-upon work. 696. Defendants breached their respective contracts with each Plaintiff by failing to comply with their binding promises regarding assistance in applying for and obtaining permanent residency and immigration status for Plaintiffs in the United States no later than 24 months after the commencement of work, and steady and ongoing work opportunities in the United States with Defendant Signal.
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into substantial debts, surrendered other employment opportunities, and incurred other financial losses.
698. Defendants’ actions evince malice and/or reckless indifference towards Plaintiffs. 699. As a direct result of Defendants’ breach, Plaintiffs have suffered direct and consequential damages, and are entitled to recover damages for the period up to and including the time that Plaintiffs were employed by Signal. Those damages include compensatory damages (including, without limitation, loss of wages, loss of opportunity, pain and suffering, mental and emotional distress, prejudgment interest, and additional economic loss from (1) recruitment and visa fees paid to Defendants; (2) expenses that Plaintiffs incurred to pay such fees, including but not limited to interest from loans; (3) medical expenses; (4) damages related to living and working conditions; and (5) mandatory housing and other fees paid to Signal), punitive damages, and attorneys’ fees in an amount to be proven at trial.
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PRAYER FOR RELIEF WHEREFORE, Plaintiffs request the following relief for the period up to and including the time that Plaintiffs were employed by Signal: 1. Compensatory relief, (including, without limitation, loss of wages, loss of opportunity, pain and suffering, mental and emotional distress, prejudgment interest, and additional economic loss from (1) recruitment and visa fees paid to Defendants; (2) expenses that Plaintiffs incurred to pay such fees, including but not limited to interest from loans; (3) medical expenses; (4) damages related to living and working conditions; and (5) mandatory housing and other fees paid to Signal); 2. Punitive damages; 3. An award of reasonable Plaintiffs’ costs, including attorneys’ fees and costs; 4. Such additional and further relief as the Court may deem proper and just.
DEMAND FOR JURY TRIAL Pursuant to Rule 38 of the Federal Rules of Civil Procedure, Plaintiffs demand trial by jury in this action of all issues so triable.
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Dated: March 3, 2014

Respectfully submitted,
LATHAM & WATKINS LLP
By: /s/ Craig A. Batchelor
Miles N. Ruthberg, pro hac vice Benton J. Campbell, pro hac vice Christopher Harris, pro hac vice Craig A. Batchelor, pro hac vice Daniel D. Adams, pro hac vice Elizabeth C. Rowland, pro hac vice Aaron M. Safane, pro hac vice 885 Third Avenue New York, New York 10022 Tel: (212) 906-1200 Fax: (212) 751-4864 E-mail: miles.ruthberg@lw.com E-mail: benton.campbell@lw.com E-mail: christopher.harris@lw.com E-mail: craig.batchelor@lw.com E-mail: daniel.adams@lw.com E-mail: elizabeth.rowland@lw.com E-mail: aaron.safane@lw.com
GORDON, ARATA, McCOLLAM, DUPLANTIS & EAGAN, LLC A. Gregory Grimsal (#06332) Steven W. Copley (#16869) 201 St. Charles Avenue 40th Floor New Orleans, Louisiana 70170 Tel: (504) 569-1834 Fax: (504) 582-1121 E-mail: ggrimsal@gordonarata.com E-mail: scopley@gordonarata.com
Attorneys for the Achari Plaintiffs

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CERTIFICATE OF SERVICE I hereby certify that on March 3, 2014, I electronically filed the foregoing with the Clerk of the Court using the ECF system which sent notification of an electronic filing to all CM/ECF participants. I further certify that I mailed the foregoing document and the notice of electronic filing by first-class mail to non-CM/ ECF participants, other than Defendant Michael Pol, litigation against whom is stayed pursuant to the automatic bankruptcy stay.
/s/ Craig A. Batchelor Craig A. Batchelor, pro hac vice

 
 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA

KURIAN DAVID, et al. Plaintiffs

CIVIL ACTION

VERSUS

No. 08-1220

SIGNAL INTERNATIONAL, LLC, et al., Defendants

SECTION “E”

Related Cases:

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION,
Plaintiff
VERSUS
SIGNAL INTERNATIONAL, LLC, et al., Defendants

CIVIL ACTION
No. 12-557 SECTION “E”

LAKSHMANAN PONNAYAN ACHARI, et al., CIVIL ACTION
Plaintiffs VERSUS
SIGNAL INTERNATIONAL, LLC, et al., Defendants

No. 13-6218 (c/w 13-6219, 13-6220, 13-6221, 14-732)
SECTION "E"

Applies To: Achari v. Signal (13-6218 c/w 13-6219, 13-6220, 13-6221) ORDER AND REASONS
Before the Court is a Motion to Dismiss Pursuant to Rule 12(b)(6)1 and a Rule 12(c)
1R. Doc. 148. All documents cited in this order were filed in the master case, Achari v. Signal (136218).
1

Motion for Judgment on the Pleadings both filed by defendant Burnett,2 as well as a Motion for Partial Dismissal under Rule 12(b)(6) filed by defendant Signal International, LLC ("Signal").3 Plaintiffs oppose all of the motions.4 Considering the briefs, the record, and the parties arguments at oral argument, the court rules as follows.
FACTUAL AND PROCEDURAL BACKGROUND Plaintiffs are citizens of India who secured visas to work in the United States for Signal in the aftermath of Hurricane Katrina. Plaintiffs allege the Defendants recruited them to work as temporary workers at Signal's facilities in Pascagoula, Mississippi. Plaintiffs further allege Defendants forced them to pay recruitment fees, as well as immigration processing and travel expenses. Plaintiffs allege that throughout their recruitment, Defendants promised them permanent residency in the United States, however, Defendants never took any steps to assist Plaintiffs in applying for or obtaining green cards. As a result of Defendants' actions, Plaintiffs claim they were discriminated against and subjected to forced labor as welders, pipefitters, and marine fabrication workers for Signal. At Signal's facilities, Plaintiffs claim Signal forced the workers to live in deplorable conditions and used various tactics to compel the Plaintiffs to continuing working. Plaintiffs originally were a part of a putative class action in David v. Signal (081220)(the "David case"). Plaintiffs are current members of the class of Indian workers on whose behalf the Equal Employment Opportunity Commission ("EEOC") brought suit in
2R. Doc. 228. The Court uses "Burnett" to collectively refer to the following defendants: Malvern C. Burnett, the Gulf Coast Immigration Law Center, LLC and the Law Offices of Malvern C. Burnett, APC.
3R. Doc. 150. 4R. Doc. 159, R. Doc. 160, R. Doc.161, R. Doc. 222, R. Doc. 223, and R. Doc. 238.
2

EEOC v. Signal (12-557)(the "EEOC case").5 After the Court denied class certification in the
David case, putative class members filed four separate actions in the Southern District of
Mississippi.6 On October 24, 2013, the four actions were consolidated and transferred to the
Eastern District of Louisiana.7 These four consolidated cases are collectively referred to
herein as the Achari cases.
In of each the Achari cases, Plaintiffs allege Signal, Burnett, and Dewan8 violated the
Trafficking Victims Protection Act of 2003 ("TVPRA") and Signal violated the Civil Rights
Act of 1866 (Section 1981).9 Additionally, Plaintiffs in the Krishnakutty case include claims
under the Racketeer Influenced and Corrupt Organizations Act ("RICO") (18 U.S.C. § 1962
et seq) and the Klu Klux Klan Act (42 U.S.C. § 1985) against Signal, Burnett, and Dewan.10
Plaintiffs in the Achari cases also allege state law claims for fraudulent misrepresentation,
5The term "class" is used collectively to describe the aggrieved individuals who the EEOC represents and does not implicate Federal Rule of Civil Procedure 23.
6Achari v. Signal (13-6218) (47 former putative class members from the David case), Chakkiyattil v. Signal (13-6219) (28 former putative class members), Krishnakutty v. Signal (13-6220) (2 former putative class members), Devassy v. Signal (13-6221) (13 former putative class members).
7R. Doc. 47. A fifth case from the Southern District of Mississippi, Singh v. Signal (14-732) was transferred to the Eastern District of Louisiana on April 24, 2014 and consolidated with the Achari cases. R. Doc. 240. These motions were filed before the Singh case was transferred to this Court.
8The Court uses "Dewan" to collectively refer to the following defendants: Global Resources, Inc., Dewan Consultants, and Sachin Dewan.
9See R. Doc. 200 (the Achari complaint); R. Doc. 199 (the Chakkiyattil complaint); R. Doc. 201 (the Krishnakutty complaint); and R. Doc. 198 (the Devassy complaint). In addition to Signal, Burnett, and Dewan, plaintiffs in each case name other defendants. In the Achari case, plaintiffs also name Michael Pol as a defendant. In the Chakkiyattil case, plaintiffs name Billy Wilks, J&M Associates, Inc., and J&M Marine, Inc. as defendants. In the Krishnakutty case, plaintiffs name Indo-Amerisoft, LLC and Kurella Rao as defendants. In the Devassy case, plaintiffs name Kurella Rao, Indo-Amerisoft, LLC and Michael Pol as defendants.
10R. Doc. 201, pp. 46-58. The Krishnakutty plaintiffs also name Kurella Rao and Indo-Amerisoft as defendants in their claims under RICO and the Klu Klux Klan Act.
3

negligent misrepresentation, and breach of contract.11 In addition, Plaintiffs in the Krishnakutty case seek relief for money had and received, and breach of fiduciary duty under Mississippi law.12
Signal and Burnett had filed motions to dismiss in the Achari cases before they were transferred from the Southern District of Mississippi and consolidated. Once the Achari cases were transferred, this Court ordered counsel for Signal and Burnett to re-file their motions to dismiss with a new submission date.13 Both Signal and Burnett filed a Motion to Dismiss under Rule 12(b)(6).14 The Plaintiffs in the Achari cases jointly filed oppositions to both motions.15 Plaintiffs in the Krishnakutty case filed a separate opposition to Burnett's motion to specifically address the arguments made with respect to their claims.16
The Court thereafter ordered Plaintiffs in each case to file an amended complaint.17 The Court also directed Signal and the Burnett Defendants to file supplemental memoranda clarifying their intention to reassert their motions to dismiss with respect to the amended
11Four complaints addressed in these motions (Achari, Chakkiyattil, Krisnakutty, and Devassy) bring state law claims under Mississippi law. The complaint in the recently transferred Singh case does not specify the law of which state its state law claims arise under.
12R. Doc. 201, pp. 65-70. 13R. Doc. 149. 14R. Doc. 148, R. Doc. 150. 15R. Doc. 159, R. Doc. 160. 16R. Doc. 161. 17R. Doc. 182. The Court instructed the plaintiffs to file amended and restated complaints specifically setting forth the defendants against which each cause of action is asserted, the specific damages sought under each cause of action, and the statute or other law on which the demand is based.
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complaints.18 Plaintiffs filed supplemental oppositions to Signal and Burnett's supplemental memoranda.19 Burnett also filed a Rule 12(c) Motion for Judgment on the Pleadings,20 which Plaintiffs opposed.21 The Court will consider each motion in turn.
STANDARD OF LAW
The Rule 12(b)(6) motions to dismiss filed by Signal and Burnett and the Burnett's
12(c) Motion for Judgment on the Pleadings are all governed by the same legal standard.
The standard for dismissal under Rule 12(c) is the same as that for dismissal for failure to
state a claim under Rule 12(b)(6). Johnson v. Johnson, 385 F.3d 503, 528 (5th Cir. 2004).
Pursuant to Federal Rule of Civil Procedure 12(b)(6), a district court may dismiss a
complaint, or any part of it, for failure to state a claim upon which relief may be granted if
the plaintiff has not set forth factual allegations in support of his claim that would entitle
him to relief. Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007); Cuvillier v. Taylor, 503
F.3d 397, 401 (5th Cir. 2007). As the Fifth Circuit explained in Gonzales v. Kay:
"Factual allegations must be enough to raise a right to relief above the speculative level." Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555, 127 S.Ct. 1955, 167 L. Ed. 2d 929 (2007). The Supreme Court recently expounded upon the Twombly standard, explaining that "[t]o survive a motion to dismiss, a complaint must contain sufficient factual matter, accepted as true, to 'state a claim to relief that is plausible on its face." Ashcroft v. Iqbal, 556 U.S. 662, 128 S.Ct. 1937, 1949, 173 L.Ed.2d 868 (2009) (quoting Twombly, 550 U.S. at 570, 127 S.Ct. 1955, 167 L.Ed.2d 929). "A Claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct
18R. Doc. 210. 19R. Doc. 222, R. Doc. 223. 20R. Doc. 228. 21R. Doc. 238.
5

alleged." Id. It follows that "where the well-pleaded facts do not permit the court to infer more than the mere possibility of misconduct, the complaint has alleged - but it has not 'show[n]' - that the pleader is entitled to relief." Id. at 1950 (quoting Fed. R. Civ. P. 8(a)(2)). 577 F.3d 600, 603 (5th Cir. 2009). The Court cannot look beyond the factual allegations in the pleadings to determine whether relief should be granted. See Spivey v. Robertson, 197 F.3d 772, 774 (5th Cir. 1999); Baker v. Putnal, 75 F.3d 190, 196 (5th Cir. 1996). In assessing the Plaintiffs' complaint, the Court must accept all well-pleaded facts as true and liberally construe all factual allegations in the light most favorable to the Plaintiffs. Spivey, 197 F.3d at 774; Lowrey v. Tex A & M Univ. Sys., 117 F.3d 242, 247 (5th Cir. 1997). "Dismissal is appropriate when the complaint 'on its face show[s] a bar to relief." Cutrer v. McMillan, 308 F. App'x 819, 820 (5th Cir. 2009) (per curiam) (unpublished) (quoting Clark v. Amoco Prod. Co., 794 F.2d 967, 970 (5th Cir. 1986)). A court may grant a motion for judgment on the pleadings when no genuine issues of material fact remain and the case can be decided as a matter of law. Erickson v. Pardus, 127 S.Ct. 2197, 2200, 167 L.Ed.2d 1081 (2007).
ANALYSIS A. Signal's Motion to Partially Dismiss for Failure to State a Claim22
Signal seeks dismissal of Plaintiffs' state law claims, claim for recruitment fees under 1981, and claim for recruitment fees under the Klu Klux Klan Act. With respect to Plaintiffs' state law claims, Signal argues those claims arise from the Plaintiffs' recruitment abroad to work in the United States, and under Mississippi law, Plaintiffs' claims are implausible.23 Similarly, Signal argues Plaintiffs' claims for recruitment fees under Section 1981 and the
22R. Doc. 150. 23R. Doc. 150, p. 18.
6

Klu Klux Klan Act arise out of events occurring abroad and those statutes do not apply extraterritorially.24
1. State Law Claims In each of the Achari cases, Plaintiffs claim that all Defendants promised to secure them permanent residency after their employment with Signal. Plaintiffs allege they paid exorbitant "recruitment fees" to the Defendants for processing immigration documents, yet Defendants failed to secure permanent residency for the Plaintiffs after their arrival in the United States. Plaintiffs also claim the Defendants misrepresented the nature of Plaintiff's employment and immigration opportunities in the United States. For the Defendants' alleged failure to fulfill their promises to secure permanent residency, Plaintiffs assert breach of contract claims under Mississippi law. For the Defendants' alleged false representations regarding Plaintiffs' opportunities for immigration and employment status, Plaintiffs assert fraudulent and negligent misrepresentation claims under Mississippi law. Signal argues the facts giving rise to Plaintiffs' state law claims involve Signal's alleged wrongdoing abroad. Signal believes the state law claims have a "foreign basis" because Plaintiffs' recruitment began in either India or the United Arab Emirates (UAE). Signal cites to Mississippi's choice-of-law rules to argue the state law claims are implausible because Mississippi law would not recognize claims arising from events occurring abroad. Additionally, the Krishnakutty Plaintiffs allege Defendants breached a fiduciary duty to Plaintiffs by failing to fulfill promises to obtain permanent residency or by misrepresenting Plaintiffs' ability to secure permanent residency. The basis of the Krishnakutty Plaintiffs'
24R. Doc. 150, p. 22.
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claims for money had and received is identical.
The questions of which state's choice of law rules apply and which state's substantive
law applies are questions of law for the Court. These issues have not yet been decided and,
as a result, Signal is not entitled to dismissal of the Plaintiffs' state law claims because it has
not established that the facts as alleged, accepted as true, fail to state a claim to relief that
is plausible on its face. The Court cannot reasonably infer the defendant is liable or not
liable for the misconduct alleged unless it knows the applicable law. Accordingly, Signal's
motion to dismiss the Plaintiffs' state law claims is denied. Signal may refile its motion to dismiss the state law claims once these choice of law issues have been decided.25
2. Claims under Section 1981 and the Klu Klux Klan Act
Plaintiffs allege Signal unlawfully subjected the Plaintiffs to discriminatory terms
and conditions of employment at Signal's facilities in Pascagoula, Mississippi based on race,
ethnicity, religion and alienage. Plaintiffs assert Signal violated 42 U.S.C. § 1981, which prohibits discrimination in employment on the basis of race.26 The Krisnakutty Plaintiffs
include a claim under the Klu Klux Klan Act (42 U.S.C. § 1985), alleging Defendants
conspired to deprive Plaintiffs of their Thirteenth Amendment rights to be free from forced
labor and involuntary servitude. Signal moves to dismiss Plaintiffs' claims under Section
25Because this Court has federal question jurisdiction and is exercising supplemental jurisdiction over Plaintiffs' state law claims, the Court must apply the law in the state in which it sits. Erie Railroad Co. v. Tompkins, 304 U.S. 64, 58 S.Ct. 817, 82 L.Ed. 1188 (1938). This includes the choice-of-law rules of the forum state. Klaxon v. Stentor Electric Manufacturing Co., 313 U.S. 487 (1941). When a case is transferred pursuant to 28 U.S.C. § 1404(a), courts apply the choice-of-law rules of the transferor state. Ferens v. John Deere, 494 U.S. 516, 525 (1990). However, whether the Ferens rule applies to cases transferred pursuant to the first-filed rule, such as this one, is unsettled. Accordingly, it is unclear which state's choice-of-law rules apply to this case, and it is unclear which state's substantive laws apply.
26Section 1981 refers to racial discrimination in the making an enforcement of contracts, but the statute has been read to provide a federal remedy against discrimination in employment on the basis of race. See Adams v. McDougal, 695 F.2d 104 (5th Cir. 1983).
8

1981 and the Klu Klux Klan Act insofar as those claims seek recovery of recruitment fees
paid abroad. Signal asserts Plaintiffs' recruitment occurred abroad and neither Section 1981
nor the Klu Klux Klan Act apply extraterritorially.
Plaintiffs' amended complaints do not seek recovery of recruitment fees under
Section 1981 or the Klu Klux Klan Act.27 Plaintiffs' claims under Section 1981 are rooted in
Signal's alleged discriminatory acts at Signal's facility in the United States. The
Krishnakutty Plaintiffs' Klu Klux Klan Act claims relate to Signal's alleged conspiracy to
deprive Plaintiffs' Thirteenth Amendment rights at Signal's Facilities in the United States.
In contrast, in each of the Plaintiffs' claims under TVPA, the Plaintiffs explicitly pray for
economic loss from recruitment fees paid to the Defendants.28 Thus, because the Plaintiffs
do not pray for recruitment fees under its Section 1981 or Klu Klux Klan Act claims, Signal's
motion to dismiss those claims is moot.
27In the Achari case, Plaintiffs seek: "compensatory damages (including, without limitation, loss of wages, loss of opportunity, pain and suffering, mental and emotional distress, prejudgment interest, and additional economic loss from (1) medical expenses; (2) damages related to living and working conditions; and (3) mandatory housing and other fees paid to Signal), punitive damages, attorneys' fees in an amount to be proven at trial." See R. Doc. 200, p. 149. Plaintiffs in the Krishnakutty case seek: "lost and unpaid wages, lost opportunities, pain and suffering (including emotional distress and humiliation), out-of-pocket expenses, and other pecuniary losses including loss of property and/or business." See R. Doc. 201, p. 57. Plaintiffs in the Chakkiyatil case seek "[C]ompensatory damages [including] housing fees paid to Signal and other charges made by Signal, adverse terms and conditions of employment resulting from discrimination (including underpayment of wages), pain, suffering, medical costs and lost wages resulting from on-the-job physical injuries related to discriminatory working conditions, damages related to living and working conditions, and damages suffered due to mental and emotional distress, as well as opportunity costs, out-of-pocket costs, and other pecuniary losses." See R. Doc. 199, p. 116. Plaintiffs in the Devassy case seek damages including: "housing fees paid to Signal and other charges made by Signal, adverse terms and conditions of employment resulting from discrimination (including underpayment of wages), pain, suffering, medical costs and lost wages resulting from on-the-job physical injuries related to discriminatory working conditions, damages related to living and working conditions, and damages suffered due to mental and emotional distress, as well as opportunity costs, out-of-pocket costs, and other pecuniary damages." See R. Doc. 198, p. 72.
28For example, in the Achari case, Plaintiffs pray for "economic loss from recruitment and visa fees paid to Defendants." R. Doc. 200, p. 147. In the Chakkiyatil case, Plaintiffs pray for "compensatory and punitive damages ... including recruitment fees." R. Doc. 199, p. 114. In the Devassy case, Plaintiffs pray for "compensatory and punitive damages, including recruitment fees..." R. Doc. 198, p. 70.
9

Accordingly, for the above stated reasons, Signal's 12(b)(6) Motion to Partially Dismiss is DENIED as to the Plaintiffs' state law claims and DENIED AS MOOT as to claims for recruiting fees under Section 1981 and the Klu Klux Klan Act. B. Burnett's 12(b)(6) Motion29
Burnett moves to dismiss the entirety of Plaintiffs' complaints, arguing the complaints only allege "unsupported and unsupportable conclusions" as to all Defendants, and do not include factual material sufficient to survive a Rule 12(b)(6) motion. Burnett additionally asserts Plaintiffs have not pled the allegations of fraud with the specificity required under Rule 9. With respect to Plaintiffs' state law claims, Burnett argues the acts alleged to form the basis of those claims occurred in India and the United Arab Emirates and are thus implausible under Mississippi law. Finally, Burnett argues Plaintiffs' state law claims are barred by the passing of the statute of limitations.
1. Sufficiency of Factual Material Alleged a. TVPA Claims
Burnett argues Plaintiffs' complaints lack factual allegations sufficient to state a claim under the TVPA. Burnett asserts Plaintiffs do not allege that Burnett ever forced Plaintiffs to work for Signal or ever threatened any Plaintiff with deportation if they refused to continue working for Signal. Burnett believes he provided legal and necessary immigration services to allow Plaintiffs to enter the United States.
Plaintiffs' complaints include two related claims under the TVPA: a claim for forced labor under 18 U.S.C. § 1589 ("Section 1589"), and a claim for trafficking under 18 U.S.C.
29R. Doc. 148.
10

§ 1590 ("Section 1590"). Under 18 U.S.C. § 1595 ("Section 1595"), an individual who is a victim of a violation under the TVPA may bring a civil action against anyone who "knowingly benefits, financially or by receiving anything of value from participation in a venture which that person know or should have known has engaged in an act in violation of [the TVPA]." 18 U.S.C. § 1595.
Plaintiffs seek relief under Section 1589, which prohibits anyone who "knowingly provides or obtains the labor or services of a person by any one of, or by any combination of, the following means: (1) by means of force, threats of force, physical restraint, or threats of physical restraint to that person or another person; (2) by means of serious harm or threats of serious harm to that person or another person; (3) by means of the abuse or threatened abuse of law or legal process; or (4) by means of any scheme, plan, or pattern intended to cause the person to believe that, if that person did not perform such labor or services, that person or another person would suffer serious harm or restraint." 18 U.S.C. § 1589.
Plaintiffs allege Burnett placed advertisements and conducted seminars in Indian cities to recruit workers for Signal, promising "employment based green cards" and permanent residency in the United States.30 Plaintiffs' claim Burnett promised them green cards in order to induce Plaintiffs to pay large fees to travel and work in the United States.31 Plaintiffs allege Burnett never took any steps to apply for permanent residency for the Plaintiffs.32 Based on their "need to repay the substantial debt and interest [they] incurred"
30See, e.g., R. Doc. 200, pp. 21-22. 31Id. at p. 22. 32Id. at p. 23.
11

to pay Burnett's recruitment fees, Plaintiffs allege they felt "intimidated into acquiescence and compelled to continue working for Signal."33 Plaintiffs allegations are sufficient to state a claim under Section 1589(a)(2) for using "serious harm" to provide or obtain Plaintiffs' labor.34
Under Section 1589(c)(2), "serious harm" includes financial harm "that is sufficiently serious ... to compel a reasonable person .. to perform or to continue performing labor services in order to avoid incurring that harm." Courts have found that threats of being in debt and being unable to repay those debts constitutes "serious harm" sufficient to survive a motion to dismiss. See Nunag-Tanedo v. East Baton Rouge Parish School Bd., 790 F. Supp. 2d 1134 (C.D. Cal. 2011); Panwar v. Access Therapies, Inc., 2013 WL 5486783 (S.D. Ind. Sept. 30, 2013). Because Plaintiffs have alleged Burnett induced them into incurring substantial debts and Plaintiffs felt compelled to continue working to repay those debts, Plaintiffs' complaints contain sufficient facts to state a claim under Section 1589(a)(2).
Plaintiffs also allege Burnett violated Section 1590 of the TVPA. Section 1590 provides a claim against any person who "knowingly recruits, harbors, transports, provides, or obtains by any means, any person for labor or services in violation of this chapter..." 18 U.S.C. § 1590. The violations of Section 1589 are included in the chapter for violations of Section 1590. Thus, because Plaintiffs have pled sufficient facts to state a claim under Section 1589, Plaintiffs have also pled sufficient facts to state a claim under Section 1590 against Burnett as a person who recruited Plaintiffs for labor in violation of Section 1589.
33See, e.g., r. Doc. 200, p. 85. 34As Plaintiffs point out in their original opposition, their allegations are also likely sufficient to state a claim under Section 1589(a)(3) for using "abuse of the legal process" to provide Plaintiffs' labor.
12

See Nunag-Tanedo, 790 F. Supp. 2d at 1147 ("Plaintiffs have sufficiently alleged that Defendants are involved in a fraudulent scheme involving forced labor, and with the intentional nature of this matter Plaintiffs have also sufficiently alleged that Defendants recruited, transported, and provided Plaintiffs for that forced labor.").
In sum, Plaintiffs claims under the TVPA are sufficiently supported by factual allegations in each complaint. Burnett insists his actions were "consistent with what would happen in the ordinary course of events in representing non-immigrant workers recruited for work in the United States."35 However, Burnett's disagreement over the version of the facts alleged in Plaintiffs' complaints is insufficient to support a motion to dismiss. The Court must accept all factual allegations in Plaintiffs' complaints as true, and Burnett has failed to show Plaintiffs' claims under the TVPA should be dismissed.
b. State Law Claims Burnett also argues Plaintiffs' complaint does not set forth sufficient factual allegations to support their state law claims for fraudulent misrepresentation, negligent misrepresentation, and breach of contract. Burnett asserts the facts alleged demonstrate a "fulfillment of Burnett's obligations to the Plaintiffs." As explained above, the questions of which state's choice of law rules apply and which state's substantive laws apply have not yet been decided. As a result, Burnett is not entitled to dismissal of the Plaintiffs' state law claims because he has not established that the facts as alleged, accepted as true, fail to state a claim to relief that is plausible on its face. The Court does find that Plaintiffs have satisfied Rule 9(b)'s requirement of pleading fraud
35R. Doc. 148, p. 6.
13

with particularity. Accordingly, Burnett's motion to dismiss the Plaintiffs' state law claims is denied. Burnett may refile his motion to dismiss the state law claims, to the extent that it is not based on Rule 9(b), once choice of law issues have been decided.
2. Extraterritoriality Burnett moves to dismiss Plaintiffs' state law claims by briefly putting forth the same argument as Signal. That is, because a portion of the facts giving rise to Plaintiffs' state law claims occurred abroad, Burnett argues those claims should be brought under the laws of India or the UAE. Burnett asserts Plaintiffs' complaint does not show a remedy exists under Indian law, thus Plaintiffs' state law claims should be dismissed. As explained above, the questions of which state's choice of law rules apply and which state's substantive laws apply have not yet been decided. As a result, Burnett is not entitled to dismissal of the Plaintiffs' state law claims because he has not established that the facts as alleged, accepted as true, fail to state a claim to relief that is plausible on its face. Accordingly, Burnett's motion to dismiss the Plaintiffs' state law claims is denied. Burnett may refile his motion to dismiss the state law claims once choice of law issues have been decided. 3. Statute of Limitations Lastly, Burnett seeks dismissal of Plaintiffs' state law claims for fraud, negligent misrepresentation and breach of contract asserting the statute of limitations under Mississippi law ran by March 8, 2011.36 As explained above, the questions of which state's choice of law rules apply and
36R. Doc. 148-1, p. 7.
14

which state's substantive laws apply have not yet been decided. As a result, Burnett is not entitled to dismissal of the Plaintiffs' state law claims because he has not established that the facts as alleged, accepted as true, fail to state a claim to relief that is plausible on its face. Accordingly, Burnett's motion to dismiss the Plaintiffs' state law claims is denied. Burnett may refile his motion to dismiss the state law claims once choice of law issues have been decided. C. Burnett's 12(c) Motion37
Burnett filed a Rule 12(c) Motion for Judgment on the Pleadings in Achari v. Signal (13-6218) seeking to dismiss Plaintiffs' claims based on the same grounds as his Rule 12(b)(6) Motion to Dismiss. For the reasons discussed above, Burnett has not carried his burden of showing dismissal is warranted. Accordingly, Burnett's 12(c) Motion for Judgment on the Pleadings is DENIED.
CONCLUSION For the above-stated reasons, IT IS ORDERED that Signal's 12(b)(6) Motion for Partial Dismissal be and hereby is DENIED as to the Plaintiffs' state law claims and DENIED AS MOOT as to claims for recruiting fees under Section 1981 and the Klu Klux Klan Act. IT IS FURTHER ORDERED that Burnett's Rule 12(b)(6) Motion for Partial Dismissal be and hereby is DENIED. IT IS FURTHER ORDERED that Burnett's Rule 12(c) Motion for Partial Judgment on the Pleadings be and hereby is DENIED.
37R. Doc. 228.
15

New Orleans, Louisiana, this 13th day of August, 2014. ____________________________ SUSIE MORGAN UNITED STATES DISTRICT JUDGE
16

 
 Case 2:13-cv-06218-SM-DEK Document 345 Filed 09/16/14 Page 1 of 6

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA

KURIAN DAVID, ET AL.

CIVIL ACTION

VERSUS

NO. 08-1220

SIGNAL INTERNATIONAL, L.L.C, ET AL.

SECTION "E" (3)

RELATED CASE:

LAKSHMANAN PNNAYAN ACHARI, ET AL.

CIVIL ACTION

VERSUS

NO. 13-6218 C/W 13-6219, 13-6220, 13-6221, 14-762

SIGNAL INTERNATIONAL, L.L.C., ET AL.

SECTION "E" (3)

RELATES TO: 08-1220, 13-6218

ORDER

On August 27, 2014, the Motion to Quash Signal's Bank Records Subpoenas [Doc. #1709]

in Civil Action No. 08-1220 (David) and the Motion to Quash Signal's Bank Records Subpoenas

[Doc. #299] in Civil Action No. 13-6218A(chari) came on for oral hearing before the undersigned.

Present were Eben Colby on behalfof the Chakkiyattil plaintiffs, Meredith Stewart on behalfof the

David plaintiffs, and Mitchell Hasenkampf and Elham Rabbani on behalf of Signal International,

L.L.C. After the oral hearing, the Court took the motions under advisement. Having reviewed the

Case 2:13-cv-06218-SM-DEK Document 345 Filed 09/16/14 Page 2 of 6
motions, the oppositions, and the case law, the Court rules as follows. I. Background
This Court has oft repeated the factual abckground of this lawsuit in earlier orderss,ee David v. Signal Int'l, L.L.C., Civ. A. No. 08-1220, 2012 WL 4344540 (E.D. La. Sept. 21, 2012), and will not do so again. The background of the related cases is near-identical to that of David. II. Law and Analysis
Defendant Signal International, L.L.C. ("Signal") served subpoenas on both Capital One and Merchant & Marines ("M&M") banks, seeking the personal bank records of hundreds of indviiduals, including the plaintiffs in the David and Achari cases.
Plaintiffs contend that the subpoenas are notcompliant with Louisiana law for two reasons. Citing Louisiana Revised Statute §6:333(C)(2), theyfirst argue that the subpoenas failed to include the required affidavit in which the subpoenaing paryt attests that a copy of the subpoena was served on each customer whose records are sought. Plaintiffs also maintain that service was not made at least fifteen business days before the return dat.e The return dates on the subpoenas were only eight days after service.
Citing case law, plaintiffs ask the Court toquash the subpoenas and order Signal to comply with Louisiana law.
Signal has withdrawn its subpoena to Capital One. The only one in dispute is thus the one propounded to M&M. Signal maintains that because plaintiffs allege financial coercion – even that Signal directed M&M to not release funds from plainitffs' own bank accounts to them – it has the right to discover how plaintiffs purchased new cars, took cross-country vacations and purchased other luxuries.
2

Case 2:13-cv-06218-SM-DEK Document 345 Filed 09/16/14 Page 3 of 6
Citing Federal Rule of Civil Procedure 45, Signal contends that the only ground on which plaintiffs may move to quash the subpoenas is th at they require the disclosure of privileged or protected matter. Signal notes that plaintiffs make no substantive objections to the subpoena.
Signal also argues that plaintiffs can not rely on Section 6:333, which specifically excludes from the statute' s scope any bank that is neither dom iciled in, nor having its principal place of business in, nor engaging in the business of banking in Louisiana. Signal notes that there is no dispute that M&M bank does not operate in Louisiana and is based in Pascagoula, Mississippi.
Even were the statute to apply, Signal argues taht the Court must apply Louisiana's conflictof-laws provisions. Under that analysis, Mississippi has the greater interest in the application ofits own laws.
Plaintiffs note that Section 6:333 provides an alternative definition for a "bank": "'Bank' shall also mean a savings bank, a savings and loan association, a company issuing credit cards, or any other business offering credit." Because M&M issues credit cards and offers credit, plaintiffs argue that Section 6:333 applies to it.
Plaintiffs also contend t hat Louisiana's interest in providing notice to individuals whose banks records have been subpoenaed does not conflitcwith Mississippi law. Because Louisiana law does not per se prevent the production of bank records (only requiring notice and an opportunity to object), plaintiffs maintain that there is no conflict with Mississippi law.
Even if there were, plaintiffs argue, Louisian a has an int erest in enforcing its bank laws. They note that here, a Louisiana law firm, acting under the authority of a Louisiana-based court, has compelled the production of bank records to a Louisiaan address. They thus contend that Louisiana has an interest in enforcing the 15-day notice to individuals.
3

Case 2:13-cv-06218-SM-DEK Document 345 Filed 09/16/14 Page 4 of 6
Plaintiffs also maintain that the subpoenas aer overbroad. They note that the subpoenas seek production of every single banking record related tohundreds of individuals. They contend that the request is all based on the testimony of one individual, Hemant Khuttan, who testified that he bought a car and that he believes that others had done so as well. Plaintiffs argue that they had no access to public transportation to obtain necessities. Som e employees thus pooled m oney t ogether to purchase a car. They contend that this hardly constitutes "luxuries."
Plaintiffs maintain that exploring hundreds ofindividuals' bank records for a period of years is not reasonably calculated to lead to the discoveryof admissible evidence. They argue that Signal should be required to specify what information it seeks. Plaintiffs also ask that they be allowed to review the information first to redact personal identifying and financial information.
For the following reasons, the Court grants themotions in part. Rule 26(b)(1) provides that “[p]arties may obtain discovery regarding any non-privileged matter that is relevant to any party's claim or defense.” Fed. R. Civ. P.26(b)(1). The rule specifies that“[r]elevant information need not be admissible at the trial if the discovery appears reasonably calculated to lead to the discovery of admissible evidence.” Id. The discovery rules are accorded a broad and liberal treatment to achieve their purpose of adequately informing litigants in civil trials. Hebert v. Lando, 441 U.S. 153, 176 (1979). Neverthe less, discovery does have “ultim ate and necessary boundaries.” Oppenheimer Fund, Inc. v. Sanders , 437 U.S. 340, 351 (1978) (quoting Hickman v. Taylor, 329 U.S. 495, 507 (1947)). Further, “it is well established that the scope of discovery is within the sound discretion of the trial court.” Coleman v. Am. Red Cross, 23 F.3d 1091, 1096 (6th Cir. 1994).
4

Case 2:13-cv-06218-SM-DEK Document 345 Filed 09/16/14 Page 5 of 6
Rule 45 governs the issuance of subpoenas, and provides that on timely motion, the issuing court must quash or m odify a subpoena if it requires disclosure of privileged or other protected matter, or otherwise subjects the subpoenaed person to undue burden. Fed. R. Civ. P. 45(c)(3). Under Rule 45(c)(1), “[a] party or attorney repsonsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena.” Fed. R. Civ. P. 45(c)(1).
The Court first pr etermits the question of whether Louisiana or Mississippi law applies. Whether M&M is a "bank" under the second definition of Section 6:333 is a merits determination for the District Court. Even were this Court to so hold, however, quashing the subpoenas at this point and on thi s ground would be no m ore than an exercise in form ality. At this point in the litigation, plaintiffs have had more than 15 days to object to the subpoenas, which they have done in their motion and in their reply.
Plaintiffs argue only that the subpoenas areoverbroad; M&M does not make this argument. While the subpoenas seek bank records f or hundreds of individuals, the Court finds that the time frames are limited and, with regard to some individuals, mere days or months. However, the Court concludes that at this late stage ofthe litigation,1 the best course of action here is to order Signal to re-propound the subpoenas and lim it them at this tim e to the nam ed plaintiffs in the David and Achari lawsuits. The return date shall be fifteen (15) days from the date of service. The Court also orders Signal to make the return of the doc uments on counsel for plaintiffs. This will allow plaintiffs to redact the documents, should circumstances so warrant, of irrelevant and/or personal

1

August 8, 2014 – the date on which plaintiffs filed their motions – was the discovery

deadline.

5

Case 2:13-cv-06218-SM-DEK Document 345 Filed 09/16/14 Page 6 of 6 information in line with the num erous protective orders in these la wsuits. Plaintif fs shall do so within fifteen (15) days of receipt of the documents and shall then produce the docum ents to Signal. III. Conclusion
For the foregoing reasons, IT IS ORDEREDthat the Motion to Quash Signasl'Bank Records Subpoenas [Doc. #1709] in Civil Action No. 08-1220 and the Motion tQo uash Signal's Bank Records Subpoenas [Doc. #299] in Civil Action No. 13-6218 are GRANTED IN PART as outlined above. New Orleans, Louisiana, this 16th day of September, 2014.
DANIEL E. KNOWLES, III UNITED STATES MAGISTRATE JUDGE
6

 
 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA

KURIAN DAVID, et al. Plaintiffs
VERSUS
SIGNAL INTERNATIONAL, LLC, et al., Defendants

CIVIL ACTION
No. 08-1220 SECTION “E”

Related Cases:

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION,
Plaintiff
VERSUS
SIGNAL INTERNATIONAL, LLC, et al., Defendants

CIVIL ACTION
No. 12-557 SECTION "E"

LAKSHMANAN PONNAYAN ACHARI, et al., Plaintiffs VERSUS
SIGNAL INTERNATIONAL, LLC, et al., Defendants

CIVIL ACTION
No. 13-6218 (c/w 13-6219, 13-6220, 13-6221, 14-732, 14-1818)
SECTION "E"

Applies To: David v. Signal (08-1220); EEOC v. Signal (12-557); Achari v. Signal (13-6218, 13-6219, 13-6220, 13-6221, 14-732)

ORDER AND REASONS Before the Court is a Motion to Certify for Interlocutory Appe al or Alternatively to Stay P ending Application for Mandamus Relie f filed by Defendants Signal
1

International, L.L.C., Signal International, Inc., and Signal Inter national Texas, G.P.

(collectively "Signal") .1 Defendants Malvern Burnett, the Law Offices of Malver

n

Burnett, A.P.C., and Gulf Coast Immigr ation Law Center, L.L.C. (the "Burnett

Defendants") have filed a similar Motion.2 The question presented is whether the Court

should certify for int erlocutory appeal its orders prohibiting th e discovery of certain

post-Signal informatio n, including immigrat ion status. For the fo llowing reasons, the

Court finds that the criteria for interlocutory appeal are not present and that a

discretionary stay pe nding the outcome of a petition for mandamus relief is not

warranted. The Motions are DENIED.

BACKGROUND3

A protective order in the above-caption ed matters prohibits Signal from

discovering, inter alia , the current immigration status of any plaintiff, the curren t

address or place of res idence of any plainti ff, and the employers or potential employers

of any plaintiff post-termination of employment with Signal. 4 Moving Defendants argue

the protective order u nduly restricts their ability to discover impeachment evidence. 5

The Court has rejected this argument on multiple occasions, finding t

hat the in

terrorem e ffect of producing the requested information outweighs Signal's interest in

unbridled discovery. Recognizing the futi lity of beating a dead hor se, Moving

Defendants now ask the Court to certify its orders upholding the protective order for

1 R. Doc. 1776 in the David Case, R. Doc. 472 in the EEOC Case, and R. Doc. 351 in the Achari Cases. 2 R. Doc. 1808 in the David Case a nd R. Doc. 3 84 in the Achari Cases. The Bur nett Defenda nts incorporate by reference the arguments set forth in Signal's motion. 3 The facts of the related cases have been detailed ad nauseum in previous orders. Familiarity is assumed. 4 R. Docs. 367 and 4 76 in the David Case, R. D oc. 285 in the EEOC Case, and R. Doc. 307 in the Achari Cases. 5 The Burnett Defenda nts also argue the protect ive order preclu des them fro m assessing the economic harm, if any, suffered by the plaintiffs.
2

interlocutory appeal. In the alternative, Moving Defendants request a discretionary stay of the above-captioned matters while they petition the Fifth Circuit Court of Appeals for a writ of mandamus.
LEGAL STANDARD An interlocutory appeal from a n on-final order in a civil case is permissible when (1) the order involves "a controlling question of law," (2) there is "substantial ground for difference of opinion" on the question pres ented, and (3) an immediate ap peal would "materially advance the ultimate termination of the litigation." 6 The district court cannot certify an order for interlocutory appe al unless all three cr iteria are present. 7 In determining whether certification is appropriate, the Court is min dful that interlocutory appeal is "exceptional " and "does not lie simply to determine t he correct ness of a judgment."8
LAW AND ANALYSIS The partie s spill much ink arguing wh ether the protective or der involves a controlling question of law on which there ex ists a substantial ground for difference of opinion. The Court need not dec ide these issues today. For the reasons explained more fully below, certificat ion is not warranted because an immediate appeal would hinder— rather than hasten—the ultimate termination of the related cases. An immediate appeal materially advances the termination of litigation if it would eliminate t he need for trial, simplify the i ssues for trial, or reduce the burden of
6 28 U.S.C. § 1292(b). 7 See A paricio v. Swan Lake, 643 F.2 d 110 9, 1 110 n.2 (5 th Cir. 1981) ( "Section 12 92(b) s ets ou t three criteria all of which must be m et before the district court may properly certify an interlocutory order for appeal.") (emphasis added). 8 Clark-Dietz & Assocs.-Eng'rs, Inc. v. Basic Constr. Co., 702 F.2d 67, 68—69 (5th Cir. 1983).
3

discovery.9 Certification of the protective order would accomplish none

of these

objectives.10 As a non-dispositive order, the revers al or affirmance of a discovery order

would seldom (if ever) eliminate the need for trial. Nor would a decision from the Fifth

Circuit simplify the issues for trial or redu ce the burden of dis covery. If anything,

vacature of the protective order would make discovery even more onerous and unwieldy.

Rather than expediting a final disposition, an interlocutory appeal would actually

delay resolution of the related cases. The David Case is set for trial in less than three

months. Even if the Fifth Circuit chose to hear the interlocutory appeal, the parties

could not realistically expect a de cision for at least six months. 11 Regardless of the Fifth

Circuit's ruling, the David Case would the n have to be returned to the Court's jur y

docket, resulting in an addition al lengthy de lay. Moreover, an extensive delay in the

David Case would likely produce a ripple effect of con tinuances in the EEOC Case and

the Achari Cases. A nd once the David Case and the related cases are finally tried,

appealable issues will almost undoubtedly still exist, 12 which co uld lead to another

round of appeals and remands.13

9 B&B Advisory Servs., LLC v. Bombardier Aerospace Corp., No. Civ. A. 02-2695, 2003 WL 22326511, a t *2 (E.D. La. Oct. 9, 2003); see also Panda Energy Int'l, Inc. v. Factory Mut. Ins., Nos. 3:11–CV–003–K, 3:10–CV–2541–K, No. 09–30453 (SGJ), and No. 09–30453 (SGJ), 2011 WL 610016, at *5 (N.D. Tex. Feb. 14, 2011) ("A n appeal materially adva nces the termination of liti gation wh en it accelerates or simplifies trial proceedings."). 10 Courts i n the Fifth C ircuit ha ve recogniz ed that a dis covery order is s eldom appropriate for interlocutory appeal. See, e.g., In re Tullius, No. EP-11-mc-365-KC., 2011 WL 50 06673, at *2 (W.D. Tex. Oct. 20 , 20 11) ( "District courts in th e Fifth Circui t are hesi tant to gran t l eave to appeal interlocutory orders relating to discovery."); Decena v. Am. Int'l Cos. (AIG), No. 11-1574, 2012 WL 1640455, at *2 (E.D. La. May 9, 2o12) ("As several courts have recognized, pretrial discovery orders will seldom meet the requirements for interlocutory appeal."). 11 As the David Plaintiffs note in their opposition memorandum, the average time for dispo sition in the Fifth Circuit is 9.3 months. See R. Doc. 1811-3 at p. 13. 12 The related cases present many issues of first impression, which increases the likelihood of appeal. 13 Such piec emeal appeals are disfavored. See Mohawk Indus., Inc. v. C arpenter, 558 U .S. 100, 106 (2009) ( "Permitting pie cemeal, preju dgment appeal s . . . under mines ' efficient ju dicial ad ministration' and encroaches upon the prerogativ es of distri ct court judges, who play a 'special role' in ma naging ongoing li tigation.) (quo ting Firestone Tire & Rubber Co. v. Ris jord, 449 U.S. 368, 374 (1981)); ClarkDietz, 702 F.2d at 69 ("The basic rule of appellate jurisdiction restricts review to final judgments, avoiding the delay and extra effort of piecemeal appeals.").
4

Having declined to certify the protective order for interlocutory appeal, the Court
now considers the alternative r elief reques ted by Moving Defendants—a stay pending
resolution of an as-of-yet-filed p etition for mandamus relief in the Fifth Circuit. There
is no automatic stay of district proceeding s while a petition for writ of mandamus is pending.14 Accordingl y, any such stay is i mposed under the dis trict court' s genera l discretionary authority.15
A district court has inherent authority to manage its docket, which includes the power to stay proceedings. 16 The moving par ty bears a " heavy burden" to dem onstrate that a stay is appropriate. 17 "Where a d iscretionary stay is proposed, something close to genuine necessity should be the mother of its invocation."18
For largely the reason s set forth above, Signal has failed to mak e the necessary
showing. The hardship and in convenience th at would result fro m a stay substantially outweighs any benefit,19 especially in light of the fact th at mandamus relief is unlikely to be granted.20 Accordingly, the Court will not issue a stay.
CONCLUSION
Signal seeks to appeal an interlo cutory ruling, the resolution of which will not
materially advance the related cases to fina l judgment. Accordin gly, the Court will not
certify the ruling for interlocutory appeal. Th e Court also finds that Signal has failed to
demonstrate that extraordinary circumstances warrant a discretionary stay.
14 Woodson v. Surgitek, Inc., 57 F.3d 1406, 1416 (5th Cir. 1995). 15 See id. 16 Landis v. N. Am. Co., 299 U.S. 248, 254 (1936). 17 Costal (Bermuda) Ltd. v. E.W. Saybolt & Co., 761 F.2d 195, 203 n.6 (5th Cir. 1985) 18 Id. 19 See L andis, 299 U. S. at 254 (instruc ting lower co urts to "wei gh competi ng i nterests an d mainta in an even balance" in deciding whether to issue a stay). 20 See In re LeBlanc, 559 F. App'x 389, 392—93 (5th Cir. 2014) (noting that writ of mandamus is rarely issued with respect to discovery orders).
5

New Orleans, Louisiana, this 14th day of October, 2014.

_________________

_______________

SUSIE

MORGAN

UNITED STATES DISTRICT JUDGE

6

 
 CaseC2a:1s3e-cMvD-0L62N1o8.-2S5M5-4DEDKocuDmoceunmt 7e6nt 3F0il4ed F0i8le/1d20/184/12P/1a4geP1aogfe31 of 3

UNITED STATES JUDICIAL PANEL on
MULTIDISTRICT LITIGATION

IN RE: SIGNAL INTERNATIONAL LLC HUMAN TRAFFICKING LITIGATION

MDL No. 2554

ORDER DENYING TRANSFER

Before the Panel:* Pursuant to 28 U.S.C. § 1407, defendants Signal International, LLC, Signal International, Inc., Signal International Texas, G.P., and Signal International Texas, L.P. (collectively, Signal) move for centralization of this litigation in the Eastern District of Louisiana. This litigation currently consists of seven actions pending in the Eastern District of Louisiana and five actions pending in the Eastern District of Texas, as listed on Schedule A. These actions involve allegations that roughly 590 Indian welders and piperfitters were lured to work for Signal through the fraudulent promise of legal and permanent work-based immigration to the United States, and that they subsequently were subjected to forced labor and other abuses at Signal’s facilities in Pascagoula, Mississippi, and Orange, Texas.
Defendants Sachin Dewan, Dewan Consultants Pvt. Ltd., Malvern C. Burnett, Gulf Coast Immigration Law Center, LLC, and the Law Offices of Malvern C. Burnett, APC, support the motion to centralize. The Equal Opportunity Employment Commission (EEOC) and some 190-plus individual plaintiffs—together comprising all the plaintiffs in the twelve actions on the motion—oppose centralization.
On the basis of the papers filed and hearing session held, we will deny plaintiffs’ motion. Although these actions share some factual questions arising out of the alleged fraudulent scheme to traffick plaintiffs into the United States to work at Signal’s facilities and the terms and conditions of employment after they were hired by Signal, we are not persuaded that Section 1407 centralization is necessary either to assure the convenience of the parties and witnesses or for the just and efficient conduct of this litigation. As both of the underlying courts have recognized, each individual plaintiff must prove how he was recruited, the abuse he allegedly suffered while working for Signal, and the damages caused to him by the alleged fraudulent scheme and discriminatory work conditions. These individualized facts very well may predominate over the common factual issues alleged by plaintiffs.
More significantly, all of the actions are progressing rapidly towards trial. Jury trial of the Mississippi plaintiffs’ claims in the first-filed David action in the Eastern District of Louisiana is scheduled for January of 2015. Fact discovery in the first two actions filed in the Eastern District of Texas will close in less than two months, and trials in those actions are also set for early- to mid-

* Judge Ellen Segal Huvelle took no part in the decision of this matter.

CaseC2a:1s3e-cMvD-0L62N1o8.-2S5M5-4DEDKocuDmoceunmt 7e6nt 3F0il4ed F0i8le/1d20/184/12P/1a4geP2aogfe32 of 3

-2-
2015. Much, if not all, of the “common” factual discovery undoubtedly has been completed already, as more than a hundred days’ worth of depositions have been conducted.
Furthermore, there has been substantialinter-district and intra-district coordination. All seven of the Louisiana actions have been assigned to Judge Susie Morgan, who has ordered five of the actions consolidated (all save the action by the EEOC) and that discovery of all the Louisiana actions be conducted in a coordinated fashion so as to avoid unnecessary duplication of efforts. Similarly, the Texas actions have been referred to the same magistrate judge. Consent orders have been entered in those actions allowing the Texas plaintiffs full access to the written discovery, document discovery, and depositions from the Louisiana actions. Thus, “informal cooperation among the involved attorneys and coordination between the involved courts seems preferable to formal centralization.” See In re Adderall XR (Amphetamine/Dextroamphetamine) Mktg., Sales Practices &Antitrust Litig., 968 F. Supp. 2d 1343, 1345 (J.P.M.L. 2013). This is particularly so where the main effect of centralization would not be to enhance convenience and efficiency, but to delay the progress of these actions, which are swiftly moving towards trial. See In re DietGoal Innovations, LLC (‘561) Patent Litig., MDL No. 2507, __ F. Supp. 2d __, 2014 WL 709762, at *1 (J.P.M.L. Feb. 19, 2014) (denying centralization where it would delay significantly advanced actions).
IT IS THEREFORE ORDERED that the motion, pursuant to 28 U.S.C. § 1407, for centralization of these actions is denied.
PANEL ON MULTIDISTRICT LITIGATION

__________________________________________ John G. Heyburn II Chairman

Marjorie O. Rendell Lewis A. Kaplan R. David Proctor

Charles R. Breyer Sarah S. Vance

CaseC2a:1s3e-cMvD-0L62N1o8.-2S5M5-4DEDKocuDmoceunmt 7e6nt 3F0il4ed F0i8le/1d20/184/12P/1a4geP3aogfe33 of 3

IN RE: SIGNAL INTERNATIONAL LLC HUMAN TRAFFICKING LITIGATION

MDL No. 2554

SCHEDULE A

Eastern District of Louisiana
DAVID, ET AL. v. SIGNAL INTERNATIONAL, LLC, ET AL., C.A. No. 2:08–01220 EQUAL EMPLOYMENT OPPORTUNITY COMMISSION v. SIGNAL
INTERNATIONAL, LLC, C.A. No. 2:12–00557 ACHARI, ET AL. v. SIGNAL INTERNATIONAL, LLC, ET AL., C.A. No. 2:13–06218 CHAKKIYATTIL, ET AL. v. SIGNAL INTERNATIONAL, LLC, ET AL.,
C.A. No. 2:13–06219 KRISHNAKUTTY, ET AL. v. SIGNAL INTERNATIONAL, LLC, ET AL.,
C.A. No. 2:13–06220 DEVASSY, ET AL. v. SIGNAL INTERNATIONAL, LLC, ET AL.,
C.A. No. 2:13–06221 SINGH, ET AL. v. SIGNAL INTERNATIONAL, LLC, ET AL., C.A. No. 2:14–00732
Eastern District of Texas
SAMUEL, ET AL. v. SIGNAL INTERNATIONAL, LLC, ET AL., C.A. No. 1:13-00323 JOSEPH, ET AL. v. SIGNAL INTERNATIONAL, LLC, ET AL., C.A. No. 1:13-00324 MEGANATHAN, ET AL. v. SIGNAL INTERNATIONAL, LLC, ET AL.,
C.A. No. 1:13-00497 KAMBALA, ET AL. v. SIGNAL INTERNATIONAL, LLC, ET AL.,
C.A. No. 1:13-00498 MARIMUTHU, ET AL. v. SIGNAL INTERNATIONAL, LLC, ET AL.,
C.A. No. 1:13-00499

 
 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA

KURIAN DAVID, et al. Plaintiffs

CIVIL ACTION

VERSUS

No. 08-1220

SIGNAL INTERNATIONAL, LLC, et al., Defendants

SECTION “E”

Related Cases:

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION,
Plaintiff
VERSUS
SIGNAL INTERNATIONAL, LLC, et al., Defendants

CIVIL ACTION
No. 12-557 SECTION “E”

LAKSHMANAN PONNAYAN ACHARI, et al., Plaintiffs
VERSUS
SIGNAL INTERNATIONAL, LLC, et al., Defendants

CIVIL ACTION
No. 13-6218 (c/w 13-6219, 13-6220, 13-6221, 14-732) SECTION "E"

Applies To: Achari v. Signal (13-6218 c/w 13-6219, 13-6220, 13-6221) ORDER AND REASONS
Before the Court is a Motion to Dismiss filed by Billy Wilks, J&M Associates, Inc., and J&M Marine & Industrial, LLC (collectively, the "J&M Defendants") in Achari v. Signal

1

(13-6218, 13-6219, 13-6220, 13-6221)(the "Achari cases").1 Plaintiffs in the Chakkiyattil case (13-6219) filed an opposition to the J&M Defendants' motion.2
The J&M Defendants move to dismiss Plaintiffs' claims in all of the Achari cases for failure to state a claim, primarily denying the factual allegations pled in Plaintiffs' complaints.3 Under Rule 12(b)(6), a district court may dismiss a complaint, or any part of it, for failure to state a claim upon which relief may be granted if the plaintiff has not set forth factual allegations in support of his claim that would entitle him to relief. Bell Atl. Corp. v. Twombly 550 U.S. 554 (2007); Cuvillier v. Taylor, 503 F.3d 397, 401 (5th Cir. 2007). In assessing the Plaintiffs' complaint, the Court must accept all well-pleaded facts as true and liberally construe all factual allegations in the light most favorable to the Plaintiffs. Lowry v. Texas A&M Univ. Sys., 117 F.3d 242, 247 (5th Cir. 1997).
The Court finds the facts pled in Plaintiffs' complaints are sufficient to support their claims against the J&M Defendants. This Court already denied a similar motion filed by the J&M Defendants seeking to dismiss the Plaintiffs' RICO claim in David v. Signal (081220)(the "David case").4 The Court is not persuaded to reach a contrary decision when the factual allegations in the Achari Plaintiffs' complaints are substantially similar to the Plaintiffs' allegations in the David case. Moreover, for the reasons set forth in the Court's Order and Reasons in the David case on the 12(c) Motion for Partial Judgment on the Pleadings and 12(b)(6) Motion to Dismiss filed by Signal and the 12(c) Motion for Partial
1R. Doc. 195. 2R. Doc. 215. 3The J&M Defendants' motion, filed pro se, does not specifically move under Rule 12(b)(6) or 12(c) to dismiss Plaintiffs' claims. However, based on the arguments made in the J&M Defendants' motion, the Court construes the motion as a 12(b)(6) motion to dismiss. 4R. Doc. 288.
2

Judgment on the Pleadings filed by Burnett,5 the Achari Plaintiffs' complaints allege sufficient facts to survive a motion to dismiss.
Accordingly, IT IS ORDERED that the J&M Defendants' Motion to Dismiss be and hereby is DENIED.
New Orleans, Louisiana, this 14th day of August, 2014. ____________________________ SUSIE MORGAN UNITED STATES DISTRICT JUDGE
5R. Doc. 1713 in the David case.
3

 
 Case 2:13-cv-06218-SM-DEK Document 534 Filed 06/04/15 Page 1 of 5

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA

KURIAN DAVID, et al. Plaintiffs
VERSUS
SIGNAL INTERNATIONAL, LLC, et al., Defendants

CIVIL ACTION
No. 08-1220 SECTION “E”

Related Cases:

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION,
Plaintiff
VERSUS
SIGNAL INTERNATIONAL, LLC, et al., Defendants

CIVIL ACTION
No. 12-557 SECTION "E"

LAKSHMANAN PONNAYAN ACHARI, et al., Plaintiffs
VERSUS
SIGNAL INTERNATIONAL, LLC, et al., Defendants

CIVIL ACTION
No. 13-6218 (c/w 13-6219, 13-6220, 13-6221, 14-732, 14-1818)
SECTION "E"

REJI SAMUEL, et al., Plaintiffs
VERSUS
SIGNAL INTERNATIONAL, LLC, et al., Defendants

CIVIL ACTION
No. 14-2811 SECTION "E"

1

Case 2:13-cv-06218-SM-DEK Document 534 Filed 06/04/15 Page 2 of 5

BIJU MAKRUKKATTU JOSEPH, et al., Plaintiffs
VERSUS SIGNAL INTERNATIONAL, LLC, et al.,

CIVIL ACTION
No. 14-2826 SECTION "E"

Applies To: Achari v. Signal (13-6218)

ORDER This matter was initially filed in the Southern District of Mississippi and transferred to the Eastern District of Louisiana under the "first-to file" rule.1 Signal has moved for summary judgment on choice of law.2 The threshold issue is whether the choice-of-law analysis is governed by Mississippi law or instead by the law of Louisiana. After resolving this issue, the Court must engage in a substantive conflicts analysis to determine the law applicable to Plaintiffs' common law claims. I. Whose Law Governs the Choice-of-Law Analysis? A federal court exercising supplemental jurisdiction over state law claims applies the forum state's choice-of-law rules.3 The Supreme Court has held that when a case is transferred pursuant to 28 U.S.C. § 1404(a),4 the transferee court must apply the choiceof-law rules that prevailed in the transferor court.5 Plaintiffs contend the so-called "Van Dusen rule" applies in this case and that therefore Mississippi's choice-of-law principles control. Plaintiffs offer two arguments in support.

1 See generally Achari v. Signal Int'l, LLC, Nos. 1:13CV222–LG–JMR, 1:13CV318–LG–JMR, 1:13CV319– LG–JMR, 2013 WL 5705660 (S.D. Miss. Oct. 18, 2013). 2 R. Doc. 333. 3 See Janvey v. Brown, 767 F.3d 430, 434 n.10 (5th Cir. 2014) 4 This statue permits change of venue "[f]or the convenience of parties and witnesses," and "in the interest of justice." 28 U.S.C. § 1404(a). 5 See generally Ferens v. John Deere Co., 494 U.S. 516 (1990).
2

Case 2:13-cv-06218-SM-DEK Document 534 Filed 06/04/15 Page 3 of 5
First, they argue a transfer order under the first-to-file rule is effectuated through
Section 1404(a) as a matter of law.6 The Court disagrees. Plaintiff has not identified any
Fifth Circuit precedent to support this novel argument,7 nor has the Court found any.
The first-to-file rule is a distinct procedural mechanism for transferring venue.8 For this
reason, district courts in the Fifth Circuit routinely distinguish between transfers under
Section 1404(a) and transfers under the first-to-file rule.9
Second, even if this case was transferred under the first-to-file rule, Plaintiffs
argue the "logic and holdings of both Van Dusen and Ferens" should still apply.10 The
Fifth Circuit has not yet addressed this issue.11 As far as this Court can tell, only four
courts have addressed whether the Van Dusen rule applies to first-to-file transfers. One
court has squarely held it does not.12 The other three—while not directly answering the
question—expressed skepticism that Van Dusen applies to transfers under the first-to-
file rule.13 The Court finds the reasoning in these cases persuasive. Furthermore,
6 See R. Doc. 347, p. 12. 7 Plaintiffs cite one district court decision from Delaware in support. 8 See White v. Peco Foods, Inc., 546 F. Supp. 2d 339, 343 (S.D. Miss. 2008) ("As other district courts have pointed out, a motion to transfer pursuant to the first-to-file rule does not depend on the presence or absence of the § 1404(a) considerations."). 9 See, e.g., Partners, L.P. v. Land Am. Am. Title Co., No. 3-08-CV-1547-O, 2008 WL 5119599, at *4 (N.D. Tex. Dec. 3, 2008) ("Even if the court does not follow the 'first-to-file' rule, transfer is warranted under 28 U.S.C. § 1404(a)."); Strukmyer, LLC v. Infinite Fin. Solutions, Inc., No. 3:13–cv–3798–L, 2013 WL 6388563, at *7 (N.D. Tex. Dec. 5, 2013) ("Plaintiff's efforts to invoke Sections 1404(a) and 1406 and contractual forum-selection clauses are misplaced under a first-to-file rule analysis. Defendants are not moving to transfer based on Section 1404(a) but rather based on the first-to-file rule."); Rooster Prods. Int'l, Inc. v. Custom Leathercraft Mfg. Co., Inc., No. SA: 04-CA-864-XR, 2005 WL 357657, at *3 n.2 (W.D. Tex. Feb. 1, 2005) (acknowledging parties were "conflating the 1404(a) analysis and the first-to-file analysis."). But see Old Republican Title Ins. Co. v. Transcontinental Title Co., No. 06-11148, 2007 WL 2284547, at *2 (E.D. La. Aug. 6, 2007) (noting that a first-to-file transfer is made pursuant to Section 1404(a)). 10 R. Doc. 347, p. 10. 11 See Chartis Specialty Ins. Co. v. Tesoro Corp., 930 F. Supp. 2d 653, 663 (W.D. Tex. 2013) (acknowledging lack of Fifth Circuit precedent). 12 See Hill-Rom Servs. Inc. v. Verses Tech., Inc., Nos. 1:03CV1227, 1:04CV1116, 2006 WL 1540851, at *10 (M.D. N.C. June 2, 2006). 13 See Volvo Constr. Equip. N. Am., Inc. v. CLM Equip. Co, Inc., 386 F.3d 581, 600 (4th Cir. 2004) ("Under these circumstances, and in light of the principles animating the Supreme Court's decision in Van Dusen, we are not at all sure that the Van Dusen precedent should be blindly and mechanically applied, as
3

Case 2:13-cv-06218-SM-DEK Document 534 Filed 06/04/15 Page 4 of 5
because the policy justifications underlying Section 1404(a) and the first-to-file rule are often in tension,14 it makes little sense to apply the Van Dusen rule—a rule developed to govern Section 1404(a) transfers—to a first-t0-file transfer. Because the Court finds the Van Dusen rule inapplicable in this case, Louisiana law governs the choice-of-law analysis. II. Choice-of-Law Analysis
The Court has already engaged in a similar Louisiana conflicts analysis in the David case.15 Because the operative facts and causes of action in David are substantially similar to the instant case,16 the David opinion guides the Court's analysis. In David, the Court held that the law of India governs the claims for fraud and negligent misrepresentation and that Mississippi law governs the claims for breach of contract and agency. There is no reason to deviate from this analysis.
the [plaintiffs] would have us do."); Chartis, 930 F. Supp. 2d at 663 ("The [defendants] jump too quickly to the conclusion that the Van Dusen rule applies when a case is transferred pursuant to the first-to-file rule."); Yancey v. Remington Arms Co., LLC, Nos. 1:12CV477, 1:12CV437, 1:10CV918, 2013 WL 5462205, at *3 (M.D. N.C. Sept. 30, 2013). 14 See Twin City Ins. Co. v. Key Energy Servs., Inc., No. H–09–0352, 2009 WL 1544255, at *7 (S.D. Tex. June 2, 2009) ("If this court were to evaluate the § 1404(a) factors, i.e., make a determination as to whether 'the convenience of parties and witnesses' and 'the interest of justice' favors venue in Houston, 28 U.S.C. § 1404(a), this court would find itself doing exactly what the first-to-file rule is designed to avoid."); Atlantic Sound Co., Inc. v. Steward, No. 5:08–cv–307(DCB)(JMR), 2009 WL 1375699, at *2 (S.D. Miss. May 15, 2009) ("The 'first-to-file' rule cannot 'trump' the transfer analysis; in other words, 'when a transfer analysis under section 1404(a) dictates that a case should be transferred, this constitutes a ‘compelling circumstance’ that warrants an abrogation from the first-filed rule.'") (quoting Terra Int'l, Inc. v. Miss. Chem. Corp., 119 F.3d 688, 697 n.12 (8th Cir. 1997)); Tillery v. Higman Barge Lines, Inc., No. 2:14–CV–40, 2014 WL 1689942, at *2 (S.D. Tex. Apr. 29, 2014). 15 See R. Doc. 2088 in No. 08-1220. 16 Even Plaintiffs acknowledge the similiarity. See R. Doc. 426, p. 4.
4

Case 2:13-cv-06218-SM-DEK Document 534 Filed 06/04/15 Page 5 of 5 CONCLUSION
The law of India governs Plaintiffs' claims of fraud and negligent misrepresentation, and the law of Mississippi governs Plaintiffs' claims of breach of contract and agency.
New Orleans, Louisiana, this 4th day of June, 2015. ________________________________ SUSIE MORGAN UNITED STATES DISTRICT JUDGE
5

 
 Case 2:13-cv-06218-SM-DEK Document 781 Filed 04/07/17 Page 1 of 2

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA

LAKSHMANAN PONNAYAN ACHARI, et al., Plaintiffs,
v.

SIGNAL INTERNATIONAL, LLC, et al., Defendants.

Related Cases:

KURIAN DAVID, et al,, v.

Plaintiffs,

SIGNAL INTERNATIONAL, LLC, et al., Defendants.

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION,
Plaintiff, v.

SIGNAL INTERNATIONAL, LLC, et al., Defendants.

CIVIL ACTION No. 13-6218 (c/w 13-6219, 136220, 13-6221, 14-732, 14-1818) Section “E”
CIVIL ACTION No. 08-1220 Section “E”
CIVIL ACTION No. 12-557 Section “E”

Applies To: No. 13-6218 (c/w 13-6219, 13-6220, 13-6221, 14-732, 14-1818); No. 08-1220 ORDER
Considering the foregoing Joint Motion for Order of Dismissal with Prejudice as against Malvern C. Burnett, the Law Offices of Malvern C. Burnett, PLC, and the Gulf Coast Immigration Law Center (the “Burnett Defendants”),
IT IS ORDERED that the motion is GRANTED;

Case 2:13-cv-06218-SM-DEK Document 781 Filed 04/07/17 Page 2 of 2 IT IS FURTHER ORDERED that all claims asserted by the Joint Plaintiffs1
against the Burnett Defendants in the Related Cases are hereby dismissed with prejudice, with the parties to bear their own respective costs.
New Orleans, Louisiana this 7th day of April, 2017. ____ _______________________________ HONORABLE SUSIE MORGAN UNITED STATES DISTRICT JUDGE
1 The “Joint Plaintiffs” includes the plaintiffs in the following civil actions: Achari v. Signal, No. 13-6218 (c/w Chakkiyattil v. Signal, 13-6219; Krishnakutty v. Signal, 13-6220; Devassy v. Signal, 13-6221; Singh v. Signal, 14732; Thomas v. Signal, 14-1818); David v. Signal, No. 08-1220 (together, the “Related Cases”).
2

 
 Case 2:13-cv-06218-SM-DEK Document 782 Filed 04/07/17 Page 1 of 2

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA

KURIAN DAVID, et al., Plaintiffs
VERSUS
SIGNAL INTERNATIONAL, LLC, et al., Defendants

CIVIL ACTION
No. 08-1220 SECTION "E"

Related Case:
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION,
Plaintiff
VERSUS
SIGNAL INTERNATIONAL, LLC, et al., Defendants

CIVIL ACTION
No. 12-557 SECTION "E"

Related Case:

LAKSHMANAN PONNAYAN ACHARI, et al., Plaintiffs

CIVIL ACTION

VERSUS

No. 13-6218 (c/w 13-6219, 13-6220, 13-6221, 14-732, 14-1818)

SIGNAL INTERNATIONAL, LLC, et al., Defendants

SECTION "E"

Applies to: No. 13-6218 (c/w 13-6219, 13-6220, 13-6221, 14-732, 14-1818)

ORDER OF PARTIAL DISMISSAL

The Court having been advised by counsel for all parties that they have firmly

agreed upon a compromise in this matter with the Dewan Defendants;

US-DOCS\82921758 5

Case 2:13-cv-06218-SM-DEK Document 782 Filed 04/07/17 Page 2 of 2 IT IS ORDERED that this action be and is hereby dismissed as to the Dewan Defendants, without costs and without prejudice to the right, upon good cause shown, on or before August 1, 2018, to reopen the action if the settlement is not consummated. In addition, the Court specifically retains jurisdiction to enforce the settlement agreement and the sealed filing entered by the Dewan Defendants as part of such settlement agreement in David v. Signal Int’l LLC, No. 08-1220, on April 6, 2017 (“Sealed Document No. 1 filed on April 6, 2017”). See Fed. R. Civ. P. 41(a)(2); Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375, 381-82 (1994); Hospitality House, Inc. v. Gilbert, 298 F.3d 424, 430 (5th Cir. 2002).
New Orleans, Louisiana this 7th day of April, 2017. _______________________ __________ HONORABLE SUSIE MORGAN UNITED STATES DISTRICT JUDGE
2
US-DOCS\82921758 5

 
 Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 1 of 250
CLOSED,MASTER,PROTO
U.S. District Court Eastern District of Louisiana (New Orleans) CIVIL DOCKET FOR CASE #: 2:13−cv−06218−SM−DEK

Achari et al v. Signal International, LLC et al Assigned to: Judge Susie Morgan Referred to: Magistrate Judge Daniel E. Knowles, III Case in other court: Mississippi Southern, 1:13−cv−00222 Cause: 28:1331 Fed. Question
Plaintiff

Date Filed: 10/23/2013 Date Terminated: 05/26/2017 Jury Demand: Both Nature of Suit: 890 Other Statutory Actions Jurisdiction: Federal Question

Lakshmanan Ponnayan Achari

represented by Daniel D. Adams LATHAM & WATKINS, LLP − New York 885 Third Avenue, Suite 1000 New York, NY 10022−4834 212/906−4602 Fax: 212/751−4864 Email: daniel.adams@lw.com LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill Lugenbuhl, Wheaton, Peck, Rankin & Hubbard (New Orleans) 60l Poydras St. Suite 2775 New Orleans, LA 70130 504−568−1990 Email: mgrabill@lawla.com LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal Gordon, Arata, Montgomery & Barnett (New Orleans) 201 St. Charles Ave. 40th Floor New Orleans, LA 70170−4000 (504) 582−1111 Email: ggrimsal@gamb.law ATTORNEY TO BE NOTICED

Aaron M. Safane Latham & Watkins, LLP (New York) 885 Third Ave. New York, NY 10022 212−906−1200 Email: aaron.safane@lw.com TERMINATED: 07/02/2015 PRO HAC VICE

Andrew Richard Lugerner Latham & Watkins, LLP (New York) 885 Third Ave. New York, NY 10022 212−906−1200 Email: andrew.lugerner@lw.com PRO HAC VICE ATTORNEY TO BE NOTICED

Benton J. Campbell LATHAM & WATKINS, LLP − New York

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 2 of 250
885 Third Avenue, Suite 1000 New York, NY 10022−4834 212/906−1200 Fax: 212/751−4864 Email: benton.campbell@lw.com TERMINATED: 04/02/2014 PRO HAC VICE
Christopher R. Harris LATHAM & WATKINS, LLP − New York 885 Third Avenue, Suite 1000 New York, NY 10022−4834 212/906−1880 Fax: 212/751−4864 Email: christopher.harris@lw.com PRO HAC VICE ATTORNEY TO BE NOTICED
Craig Alan Batchelor Latham & Watkins, LLP (New York) 885 Third Ave. New York, NY 10022 212−906−1200 Email: craig.batchelor@lw.com TERMINATED: 11/19/2014 PRO HAC VICE ATTORNEY TO BE NOTICED
Elizabeth C. Rowland Latham & Watkins, LLP (New York) 885 Third Ave. New York, NY 10022 212−906−1200 Email: elizabeth.rowland@lw.com PRO HAC VICE ATTORNEY TO BE NOTICED
Eric Marshall Broad Latham & Watkins, LLP (New York) 885 Third Ave. New York, NY 10022 212−906−1200 Email: eric.broad@lw.com PRO HAC VICE ATTORNEY TO BE NOTICED
Eric L. Taffet Latham & Watkins, LLP (New York) 885 Third Ave. New York, NY 10022 212−906−1200 Email: eric.taffet@lw.com PRO HAC VICE ATTORNEY TO BE NOTICED
Grant F. Wahlquist Latham & Watkins, LLP (New York) 885 Third Ave. New York, NY 10022 212−906−1200 Email: grant.wahlquist@lw.com TERMINATED: 03/08/2017 PRO HAC VICE ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 3 of 250
H. Gregory Baker LATHAM & WATKINS, LLP − New York 885 Third Avenue, Suite 1000 New York, NY 10022−4834 212/906−2941 Fax: 212/751−4864 Email: gregory.baker@lw.com TERMINATED: 12/10/2013 PRO HAC VICE
Jacob A. Walker Skadden, Arps, Slate, Meagher & Flom, LLP (Boston) One Beacon St. Boston, MA 02108 617−573−4800 Email: jacob.walker@skadden.com TERMINATED: 09/09/2015 PRO HAC VICE
Jennifer Greenberg LATHAM & WATKINS, LLP − New York 885 Third Avenue, Suite 1000 New York, NY 10022−4834 212/906−1871 Fax: 212/751−4864 Email: jennifer.greenberg@lw.com TERMINATED: 12/10/2013 PRO HAC VICE
Jessica D. Rostoker Latham & Watkins, LLP (New York) 885 Third Ave. New York, NY 10022 212−906−1200 Email: jessica.rostoker@lw.com PRO HAC VICE ATTORNEY TO BE NOTICED
Katelyn M. Beaudette Latham & Watkins, LLP (New York) 885 Third Ave. New York, NY 10022 212−906−1200 Email: katelyn.beaudette@lw.com TERMINATED: 11/30/2016 PRO HAC VICE
Kirk A. Wilkinson Latham & Watkins, LLP (Los Angeles) 355 South Grand Ave. Suite 4000 Los Angeles, CA 90071 213−485−1234 Email: kirk.wilkinson@lw.com PRO HAC VICE ATTORNEY TO BE NOTICED
Matthew S. Salerno Latham & Watkins, LLP (New York) 885 Third Ave. New York, NY 10022 212−906−1200 Email: matthew.salerno@lw.com PRO HAC VICE ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 4 of 250
Michael A. Romey Latham & Watkins, LLP (Los Angeles) 355 South Grand Ave. Suite 4000 Los Angeles, CA 90071 213−485−1234 Email: michael.romey@lw.com PRO HAC VICE ATTORNEY TO BE NOTICED
Michael R. Walsh Skadden, Arps, Slate, Meagher & Flom, LLP (Boston) One Beacon St. Boston, MA 02108 617−573−4800 Email: michael.walsh@skadden.com PRO HAC VICE ATTORNEY TO BE NOTICED
Miles N. Ruthberg LATHAM & WATKINS, LLP − New York 885 Third Avenue, Suite 1000 New York, NY 10022−4834 212/906−1200 Fax: 212/751−4864 Email: miles.ruthberg@lw.com PRO HAC VICE ATTORNEY TO BE NOTICED
Rebekah L. Soule Latham & Watkins, LLP (New York) 885 Third Ave. New York, NY 10022 212−906−1200 Email: rebekah.soule@lw.com PRO HAC VICE ATTORNEY TO BE NOTICED
Renee E. Plexousakis Latham & Watkins, LLP (New York) 885 Third Ave. New York, NY 10022 212−906−1200 Email: renee.plexousakis@lw.com PRO HAC VICE ATTORNEY TO BE NOTICED
Robert B. McDuff Robert McDuff, Attorney at Law 767 N. Congress St. Jackson, MS 39202 (601) 969−0802 Email: RBM@McDuffLaw.com TERMINATED: 12/27/2013
Sadie Holzman Diaz Latham & Watkins, LLP (New York) 885 Third Ave. New York, NY 10022 212−906−1200 Email: sadie.diaz@lw.com PRO HAC VICE ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 5 of 250

Sarah C. Chandrika Latham & Watkins, LLP (New York) 885 Third Ave. New York, NY 10022 212−906−1200 Email: sarah.chandrika@lw.com PRO HAC VICE ATTORNEY TO BE NOTICED

Steven W. Copley Gordon, Arata, Montgomery & Barnett (New Orleans) 201 St. Charles Ave. 40th Floor New Orleans, LA 70170−4000 (504) 582−1111 Email: scopley@gamb.law ATTORNEY TO BE NOTICED

Zachary L. Rowen Latham & Watkins, LLP (New York) 885 Third Ave. New York, NY 10022 212−906−1200 Email: zachary.rowen@lw.com PRO HAC VICE ATTORNEY TO BE NOTICED

Plaintiff Kodakeril Baby Biji

represented by Daniel D. Adams (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Andrew Richard Lugerner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Benton J. Campbell (See above for address) TERMINATED: 04/02/2014 PRO HAC VICE

Christopher R. Harris (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Elizabeth C. Rowland (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Eric Marshall Broad

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 6 of 250
(See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric L. Taffet (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Grant F. Wahlquist (See above for address) TERMINATED: 03/08/2017 PRO HAC VICE ATTORNEY TO BE NOTICED
H. Gregory Baker (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jacob A. Walker (See above for address) TERMINATED: 09/09/2015 PRO HAC VICE
Jennifer Greenberg (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jessica D. Rostoker (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Katelyn M. Beaudette (See above for address) TERMINATED: 11/30/2016 PRO HAC VICE
Kirk A. Wilkinson (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Matthew S. Salerno (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael A. Romey (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael R. Walsh (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Miles N. Ruthberg (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 7 of 250

Rebekah L. Soule (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Renee E. Plexousakis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Sadie Holzman Diaz (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Sarah C. Chandrika (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Zachary L. Rowen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Plaintiff Xavier Disoliyan

represented by Daniel D. Adams (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Andrew Richard Lugerner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Benton J. Campbell (See above for address) TERMINATED: 04/02/2014 PRO HAC VICE

Christopher R. Harris (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Elizabeth C. Rowland (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 8 of 250
Eric Marshall Broad (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric L. Taffet (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Grant F. Wahlquist (See above for address) TERMINATED: 03/08/2017 PRO HAC VICE ATTORNEY TO BE NOTICED
H. Gregory Baker (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jacob A. Walker (See above for address) TERMINATED: 09/09/2015 PRO HAC VICE
Jennifer Greenberg (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jessica D. Rostoker (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Katelyn M. Beaudette (See above for address) TERMINATED: 11/30/2016 PRO HAC VICE
Kirk A. Wilkinson (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Matthew S. Salerno (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael A. Romey (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael R. Walsh (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Miles N. Ruthberg (See above for address) PRO HAC VICE

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 9 of 250

ATTORNEY TO BE NOTICED

Rebekah L. Soule (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Renee E. Plexousakis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Sadie Holzman Diaz (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Sarah C. Chandrika (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Zachary L. Rowen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Plaintiff
Rajankunju Geevarghese

represented by Daniel D. Adams (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Andrew Richard Lugerner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Benton J. Campbell (See above for address) TERMINATED: 04/02/2014 PRO HAC VICE

Christopher R. Harris (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Elizabeth C. Rowland (See above for address)

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 10 of 250
PRO HAC VICE ATTORNEY TO BE NOTICED
Eric Marshall Broad (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric L. Taffet (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Grant F. Wahlquist (See above for address) TERMINATED: 03/08/2017 PRO HAC VICE ATTORNEY TO BE NOTICED
H. Gregory Baker (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jacob A. Walker (See above for address) TERMINATED: 09/09/2015 PRO HAC VICE
Jennifer Greenberg (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jessica D. Rostoker (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Katelyn M. Beaudette (See above for address) TERMINATED: 11/30/2016 PRO HAC VICE
Kirk A. Wilkinson (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Matthew S. Salerno (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael A. Romey (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael R. Walsh (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Miles N. Ruthberg

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 11 of 250

(See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Rebekah L. Soule (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Renee E. Plexousakis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Sadie Holzman Diaz (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Sarah C. Chandrika (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Zachary L. Rowen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Plaintiff Jomon George

represented by Daniel D. Adams (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Andrew Richard Lugerner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Benton J. Campbell (See above for address) TERMINATED: 04/02/2014 PRO HAC VICE

Christopher R. Harris (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 12 of 250
Elizabeth C. Rowland (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric Marshall Broad (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric L. Taffet (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Grant F. Wahlquist (See above for address) TERMINATED: 03/08/2017 PRO HAC VICE ATTORNEY TO BE NOTICED
H. Gregory Baker (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jacob A. Walker (See above for address) TERMINATED: 09/09/2015 PRO HAC VICE
Jennifer Greenberg (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jessica D. Rostoker (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Katelyn M. Beaudette (See above for address) TERMINATED: 11/30/2016 PRO HAC VICE
Kirk A. Wilkinson (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Matthew S. Salerno (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael A. Romey (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael R. Walsh (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 13 of 250

Miles N. Ruthberg (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Rebekah L. Soule (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Renee E. Plexousakis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Sadie Holzman Diaz (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Sarah C. Chandrika (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Zachary L. Rowen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Plaintiff Shaiju Vadakkal George

represented by Daniel D. Adams (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Andrew Richard Lugerner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Benton J. Campbell (See above for address) TERMINATED: 04/02/2014 PRO HAC VICE

Christopher R. Harris (See above for address) PRO HAC VICE

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 14 of 250
ATTORNEY TO BE NOTICED
Elizabeth C. Rowland (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric Marshall Broad (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric L. Taffet (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Grant F. Wahlquist (See above for address) TERMINATED: 03/08/2017 PRO HAC VICE ATTORNEY TO BE NOTICED
H. Gregory Baker (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jacob A. Walker (See above for address) TERMINATED: 09/09/2015 PRO HAC VICE
Jennifer Greenberg (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jessica D. Rostoker (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Katelyn M. Beaudette (See above for address) TERMINATED: 11/30/2016 PRO HAC VICE
Kirk A. Wilkinson (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Matthew S. Salerno (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael A. Romey (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael R. Walsh (See above for address)

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 15 of 250

PRO HAC VICE ATTORNEY TO BE NOTICED

Miles N. Ruthberg (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Rebekah L. Soule (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Renee E. Plexousakis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Sadie Holzman Diaz (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Sarah C. Chandrika (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Zachary L. Rowen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Plaintiff
Mouleswararao Guntamukkala

represented by Daniel D. Adams (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Andrew Richard Lugerner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Benton J. Campbell (See above for address) TERMINATED: 04/02/2014 PRO HAC VICE

Christopher R. Harris

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 16 of 250
(See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Elizabeth C. Rowland (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric Marshall Broad (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric L. Taffet (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Grant F. Wahlquist (See above for address) TERMINATED: 03/08/2017 PRO HAC VICE ATTORNEY TO BE NOTICED
H. Gregory Baker (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jacob A. Walker (See above for address) TERMINATED: 09/09/2015 PRO HAC VICE
Jennifer Greenberg (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jessica D. Rostoker (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Katelyn M. Beaudette (See above for address) TERMINATED: 11/30/2016 PRO HAC VICE
Kirk A. Wilkinson (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Matthew S. Salerno (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael A. Romey (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 17 of 250

Michael R. Walsh (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Miles N. Ruthberg (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Rebekah L. Soule (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Renee E. Plexousakis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Sadie Holzman Diaz (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Sarah C. Chandrika (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Zachary L. Rowen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Plaintiff Joy Jacob

represented by Daniel D. Adams (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Andrew Richard Lugerner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Benton J. Campbell (See above for address) TERMINATED: 04/02/2014 PRO HAC VICE

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 18 of 250
Christopher R. Harris (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Elizabeth C. Rowland (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric Marshall Broad (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric L. Taffet (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Grant F. Wahlquist (See above for address) TERMINATED: 03/08/2017 PRO HAC VICE ATTORNEY TO BE NOTICED
H. Gregory Baker (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jacob A. Walker (See above for address) TERMINATED: 09/09/2015 PRO HAC VICE
Jennifer Greenberg (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jessica D. Rostoker (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Katelyn M. Beaudette (See above for address) TERMINATED: 11/30/2016 PRO HAC VICE
Kirk A. Wilkinson (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Matthew S. Salerno (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael A. Romey (See above for address) PRO HAC VICE

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 19 of 250

ATTORNEY TO BE NOTICED

Michael R. Walsh (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Miles N. Ruthberg (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Rebekah L. Soule (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Renee E. Plexousakis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Sadie Holzman Diaz (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Sarah C. Chandrika (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Zachary L. Rowen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Plaintiff Biju John

represented by Daniel D. Adams (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Andrew Richard Lugerner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Benton J. Campbell (See above for address)

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 20 of 250
TERMINATED: 04/02/2014 PRO HAC VICE
Christopher R. Harris (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Elizabeth C. Rowland (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric Marshall Broad (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric L. Taffet (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Grant F. Wahlquist (See above for address) TERMINATED: 03/08/2017 PRO HAC VICE ATTORNEY TO BE NOTICED
H. Gregory Baker (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jacob A. Walker (See above for address) TERMINATED: 09/09/2015 PRO HAC VICE
Jennifer Greenberg (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jessica D. Rostoker (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Katelyn M. Beaudette (See above for address) TERMINATED: 11/30/2016 PRO HAC VICE
Kirk A. Wilkinson (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Matthew S. Salerno (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael A. Romey

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 21 of 250

(See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Michael R. Walsh (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Miles N. Ruthberg (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Rebekah L. Soule (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Renee E. Plexousakis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Sadie Holzman Diaz (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Sarah C. Chandrika (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Zachary L. Rowen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Plaintiff Shibu Joseph

represented by Daniel D. Adams (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Andrew Richard Lugerner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 22 of 250
Benton J. Campbell (See above for address) TERMINATED: 04/02/2014 PRO HAC VICE
Christopher R. Harris (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Elizabeth C. Rowland (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric Marshall Broad (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric L. Taffet (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Grant F. Wahlquist (See above for address) TERMINATED: 03/08/2017 PRO HAC VICE ATTORNEY TO BE NOTICED
H. Gregory Baker (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jacob A. Walker (See above for address) TERMINATED: 09/09/2015 PRO HAC VICE
Jennifer Greenberg (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jessica D. Rostoker (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Katelyn M. Beaudette (See above for address) TERMINATED: 11/30/2016 PRO HAC VICE
Kirk A. Wilkinson (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Matthew S. Salerno (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 23 of 250

Michael A. Romey (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Michael R. Walsh (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Miles N. Ruthberg (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Rebekah L. Soule (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Renee E. Plexousakis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Sadie Holzman Diaz (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Sarah C. Chandrika (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Zachary L. Rowen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Plaintiff
Sunilkumar Marottikkal Kuttan

represented by Daniel D. Adams (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Andrew Richard Lugerner (See above for address) PRO HAC VICE

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 24 of 250
ATTORNEY TO BE NOTICED
Benton J. Campbell (See above for address) TERMINATED: 04/02/2014 PRO HAC VICE
Christopher R. Harris (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Elizabeth C. Rowland (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric Marshall Broad (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric L. Taffet (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Grant F. Wahlquist (See above for address) TERMINATED: 03/08/2017 PRO HAC VICE ATTORNEY TO BE NOTICED
H. Gregory Baker (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jacob A. Walker (See above for address) TERMINATED: 09/09/2015 PRO HAC VICE
Jennifer Greenberg (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jessica D. Rostoker (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Katelyn M. Beaudette (See above for address) TERMINATED: 11/30/2016 PRO HAC VICE
Kirk A. Wilkinson (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Matthew S. Salerno (See above for address)

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 25 of 250

PRO HAC VICE ATTORNEY TO BE NOTICED

Michael A. Romey (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Michael R. Walsh (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Miles N. Ruthberg (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Rebekah L. Soule (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Renee E. Plexousakis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Sadie Holzman Diaz (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Sarah C. Chandrika (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Zachary L. Rowen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Plaintiff
Parshottam Ramchandra Mangani

represented by Daniel D. Adams (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Andrew Richard Lugerner

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 26 of 250
(See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Benton J. Campbell (See above for address) TERMINATED: 04/02/2014 PRO HAC VICE
Christopher R. Harris (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Elizabeth C. Rowland (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric Marshall Broad (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric L. Taffet (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Grant F. Wahlquist (See above for address) TERMINATED: 03/08/2017 PRO HAC VICE ATTORNEY TO BE NOTICED
H. Gregory Baker (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jacob A. Walker (See above for address) TERMINATED: 09/09/2015 PRO HAC VICE
Jennifer Greenberg (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jessica D. Rostoker (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Katelyn M. Beaudette (See above for address) TERMINATED: 11/30/2016 PRO HAC VICE
Kirk A. Wilkinson (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 27 of 250

Matthew S. Salerno (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Michael A. Romey (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Michael R. Walsh (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Miles N. Ruthberg (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Rebekah L. Soule (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Renee E. Plexousakis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Sadie Holzman Diaz (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Sarah C. Chandrika (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Zachary L. Rowen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Plaintiff
Prakash Moses Kanagiah Manonmoni

represented by Daniel D. Adams (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 28 of 250
Andrew Richard Lugerner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Benton J. Campbell (See above for address) TERMINATED: 04/02/2014 PRO HAC VICE
Christopher R. Harris (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Elizabeth C. Rowland (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric Marshall Broad (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric L. Taffet (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Grant F. Wahlquist (See above for address) TERMINATED: 03/08/2017 PRO HAC VICE ATTORNEY TO BE NOTICED
H. Gregory Baker (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jacob A. Walker (See above for address) TERMINATED: 09/09/2015 PRO HAC VICE
Jennifer Greenberg (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jessica D. Rostoker (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Katelyn M. Beaudette (See above for address) TERMINATED: 11/30/2016 PRO HAC VICE
Kirk A. Wilkinson (See above for address) PRO HAC VICE

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 29 of 250

ATTORNEY TO BE NOTICED

Matthew S. Salerno (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Michael A. Romey (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Michael R. Walsh (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Miles N. Ruthberg (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Rebekah L. Soule (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Renee E. Plexousakis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Sadie Holzman Diaz (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Sarah C. Chandrika (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Zachary L. Rowen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Plaintiff Adharsan Manuel

represented by Daniel D. Adams (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 30 of 250
(See above for address) ATTORNEY TO BE NOTICED
Andrew Richard Lugerner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Benton J. Campbell (See above for address) TERMINATED: 04/02/2014 PRO HAC VICE
Christopher R. Harris (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Elizabeth C. Rowland (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric Marshall Broad (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric L. Taffet (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Grant F. Wahlquist (See above for address) TERMINATED: 03/08/2017 PRO HAC VICE ATTORNEY TO BE NOTICED
H. Gregory Baker (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jacob A. Walker (See above for address) TERMINATED: 09/09/2015 PRO HAC VICE
Jennifer Greenberg (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jessica D. Rostoker (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Katelyn M. Beaudette (See above for address) TERMINATED: 11/30/2016 PRO HAC VICE
Kirk A. Wilkinson

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 31 of 250

(See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Matthew S. Salerno (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Michael A. Romey (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Michael R. Walsh (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Miles N. Ruthberg (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Rebekah L. Soule (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Renee E. Plexousakis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Sadie Holzman Diaz (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Sarah C. Chandrika (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Zachary L. Rowen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Plaintiff
Jacob Mazhukkattu Mathew

represented by Daniel D. Adams (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 32 of 250
A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED
Andrew Richard Lugerner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Benton J. Campbell (See above for address) TERMINATED: 04/02/2014 PRO HAC VICE
Christopher R. Harris (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Elizabeth C. Rowland (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric Marshall Broad (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric L. Taffet (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Grant F. Wahlquist (See above for address) TERMINATED: 03/08/2017 PRO HAC VICE ATTORNEY TO BE NOTICED
H. Gregory Baker (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jacob A. Walker (See above for address) TERMINATED: 09/09/2015 PRO HAC VICE
Jennifer Greenberg (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jessica D. Rostoker (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Katelyn M. Beaudette (See above for address) TERMINATED: 11/30/2016 PRO HAC VICE

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 33 of 250

Plaintiff Johny Mathew

Kirk A. Wilkinson (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Matthew S. Salerno (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael A. Romey (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael R. Walsh (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Miles N. Ruthberg (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Rebekah L. Soule (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Renee E. Plexousakis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Robert B. McDuff (See above for address) TERMINATED: 12/27/2013
Sadie Holzman Diaz (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Sarah C. Chandrika (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Zachary L. Rowen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
represented by Daniel D. Adams (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Meredith S. Grabill (See above for address)

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 34 of 250
LEAD ATTORNEY ATTORNEY TO BE NOTICED
A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED
Andrew Richard Lugerner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Benton J. Campbell (See above for address) TERMINATED: 04/02/2014 PRO HAC VICE
Christopher R. Harris (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Elizabeth C. Rowland (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric Marshall Broad (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric L. Taffet (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Grant F. Wahlquist (See above for address) TERMINATED: 03/08/2017 PRO HAC VICE ATTORNEY TO BE NOTICED
H. Gregory Baker (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jacob A. Walker (See above for address) TERMINATED: 09/09/2015 PRO HAC VICE
Jennifer Greenberg (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jessica D. Rostoker (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Katelyn M. Beaudette (See above for address)

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 35 of 250

TERMINATED: 11/30/2016 PRO HAC VICE

Kirk A. Wilkinson (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Matthew S. Salerno (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Michael A. Romey (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Michael R. Walsh (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Miles N. Ruthberg (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Rebekah L. Soule (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Renee E. Plexousakis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Sadie Holzman Diaz (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Sarah C. Chandrika (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Zachary L. Rowen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Plaintiff Nandhakumar Nagaraj

represented by Daniel D. Adams (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 36 of 250
Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED
Andrew Richard Lugerner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Benton J. Campbell (See above for address) TERMINATED: 04/02/2014 PRO HAC VICE
Christopher R. Harris (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Elizabeth C. Rowland (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric Marshall Broad (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric L. Taffet (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Grant F. Wahlquist (See above for address) TERMINATED: 03/08/2017 PRO HAC VICE ATTORNEY TO BE NOTICED
H. Gregory Baker (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jacob A. Walker (See above for address) TERMINATED: 09/09/2015 PRO HAC VICE
Jennifer Greenberg (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jessica D. Rostoker (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 37 of 250

Katelyn M. Beaudette (See above for address) TERMINATED: 11/30/2016 PRO HAC VICE

Kirk A. Wilkinson (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Matthew S. Salerno (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Michael A. Romey (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Michael R. Walsh (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Miles N. Ruthberg (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Rebekah L. Soule (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Renee E. Plexousakis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Sadie Holzman Diaz (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Sarah C. Chandrika (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Zachary L. Rowen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Plaintiff
Shaji Veluthalakuzhiyil Nanoo

represented by Daniel D. Adams (See above for address) LEAD ATTORNEY PRO HAC VICE

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 38 of 250
ATTORNEY TO BE NOTICED
Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED
Andrew Richard Lugerner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Benton J. Campbell (See above for address) TERMINATED: 04/02/2014 PRO HAC VICE
Christopher R. Harris (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Elizabeth C. Rowland (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric Marshall Broad (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric L. Taffet (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Grant F. Wahlquist (See above for address) TERMINATED: 03/08/2017 PRO HAC VICE ATTORNEY TO BE NOTICED
H. Gregory Baker (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jacob A. Walker (See above for address) TERMINATED: 09/09/2015 PRO HAC VICE
Jennifer Greenberg (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jessica D. Rostoker (See above for address) PRO HAC VICE

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 39 of 250

ATTORNEY TO BE NOTICED

Katelyn M. Beaudette (See above for address) TERMINATED: 11/30/2016 PRO HAC VICE

Kirk A. Wilkinson (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Matthew S. Salerno (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Michael A. Romey (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Michael R. Walsh (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Miles N. Ruthberg (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Rebekah L. Soule (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Renee E. Plexousakis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Sadie Holzman Diaz (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Sarah C. Chandrika (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Zachary L. Rowen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Plaintiff
Mangalan Chandrasekharan Pillai

represented by Daniel D. Adams (See above for address)

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 40 of 250
LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED
Andrew Richard Lugerner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Benton J. Campbell (See above for address) TERMINATED: 04/02/2014 PRO HAC VICE
Christopher R. Harris (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Elizabeth C. Rowland (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric Marshall Broad (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric L. Taffet (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Grant F. Wahlquist (See above for address) TERMINATED: 03/08/2017 PRO HAC VICE ATTORNEY TO BE NOTICED
H. Gregory Baker (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jacob A. Walker (See above for address) TERMINATED: 09/09/2015 PRO HAC VICE
Jennifer Greenberg (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jessica D. Rostoker

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 41 of 250
(See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Katelyn M. Beaudette (See above for address) TERMINATED: 11/30/2016 PRO HAC VICE
Kirk A. Wilkinson (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Matthew S. Salerno (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael A. Romey (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael R. Walsh (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Miles N. Ruthberg (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Rebekah L. Soule (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Renee E. Plexousakis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Robert B. McDuff (See above for address) TERMINATED: 12/27/2013
Sadie Holzman Diaz (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Sarah C. Chandrika (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Zachary L. Rowen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Plaintiff

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 42 of 250

Radhakrishna Pillai Sivarama Pillai

represented by Daniel D. Adams (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Andrew Richard Lugerner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Benton J. Campbell (See above for address) TERMINATED: 04/02/2014 PRO HAC VICE

Christopher R. Harris (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Elizabeth C. Rowland (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Eric Marshall Broad (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Eric L. Taffet (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Grant F. Wahlquist (See above for address) TERMINATED: 03/08/2017 PRO HAC VICE ATTORNEY TO BE NOTICED

H. Gregory Baker (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE

Jacob A. Walker (See above for address) TERMINATED: 09/09/2015 PRO HAC VICE

Jennifer Greenberg (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 43 of 250
Jessica D. Rostoker (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Katelyn M. Beaudette (See above for address) TERMINATED: 11/30/2016 PRO HAC VICE
Kirk A. Wilkinson (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Matthew S. Salerno (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael A. Romey (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael R. Walsh (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Miles N. Ruthberg (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Rebekah L. Soule (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Renee E. Plexousakis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Robert B. McDuff (See above for address) TERMINATED: 12/27/2013
Sadie Holzman Diaz (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Sarah C. Chandrika (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Zachary L. Rowen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 44 of 250

Plaintiff Aby Molathu Poulose

represented by Daniel D. Adams (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED
Andrew Richard Lugerner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Benton J. Campbell (See above for address) TERMINATED: 04/02/2014 PRO HAC VICE
Christopher R. Harris (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Elizabeth C. Rowland (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric Marshall Broad (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric L. Taffet (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Grant F. Wahlquist (See above for address) TERMINATED: 03/08/2017 PRO HAC VICE ATTORNEY TO BE NOTICED
H. Gregory Baker (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jacob A. Walker (See above for address) TERMINATED: 09/09/2015 PRO HAC VICE
Jennifer Greenberg (See above for address)

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 45 of 250
TERMINATED: 12/10/2013 PRO HAC VICE
Jessica D. Rostoker (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Katelyn M. Beaudette (See above for address) TERMINATED: 11/30/2016 PRO HAC VICE
Kirk A. Wilkinson (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Matthew S. Salerno (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael A. Romey (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael R. Walsh (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Miles N. Ruthberg (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Rebekah L. Soule (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Renee E. Plexousakis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Robert B. McDuff (See above for address) TERMINATED: 12/27/2013
Sadie Holzman Diaz (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Sarah C. Chandrika (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Zachary L. Rowen (See above for address) PRO HAC VICE

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 46 of 250

ATTORNEY TO BE NOTICED

Plaintiff Justin Poulose

represented by Daniel D. Adams (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Andrew Richard Lugerner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Benton J. Campbell (See above for address) TERMINATED: 04/02/2014 PRO HAC VICE

Christopher R. Harris (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Elizabeth C. Rowland (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Eric Marshall Broad (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Eric L. Taffet (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Grant F. Wahlquist (See above for address) TERMINATED: 03/08/2017 PRO HAC VICE ATTORNEY TO BE NOTICED

H. Gregory Baker (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE

Jacob A. Walker (See above for address) TERMINATED: 09/09/2015 PRO HAC VICE

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 47 of 250
Jennifer Greenberg (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jessica D. Rostoker (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Katelyn M. Beaudette (See above for address) TERMINATED: 11/30/2016 PRO HAC VICE
Matthew S. Salerno (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael A. Romey (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael R. Walsh (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Miles N. Ruthberg (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Rebekah L. Soule (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Renee E. Plexousakis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Robert B. McDuff (See above for address) TERMINATED: 12/27/2013
Sadie Holzman Diaz (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Sarah C. Chandrika (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Zachary L. Rowen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Plaintiff

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 48 of 250

Appunni Arul Prakash

represented by Daniel D. Adams (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Andrew Richard Lugerner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Benton J. Campbell (See above for address) TERMINATED: 04/02/2014 PRO HAC VICE

Christopher R. Harris (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Elizabeth C. Rowland (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Eric Marshall Broad (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Eric L. Taffet (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Grant F. Wahlquist (See above for address) TERMINATED: 03/08/2017 PRO HAC VICE ATTORNEY TO BE NOTICED

H. Gregory Baker (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE

Jacob A. Walker (See above for address) TERMINATED: 09/09/2015 PRO HAC VICE

Jennifer Greenberg (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 49 of 250
Jessica D. Rostoker (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Katelyn M. Beaudette (See above for address) TERMINATED: 11/30/2016 PRO HAC VICE
Kirk A. Wilkinson (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Matthew S. Salerno (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael A. Romey (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael R. Walsh (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Miles N. Ruthberg (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Rebekah L. Soule (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Renee E. Plexousakis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Robert B. McDuff (See above for address) TERMINATED: 12/27/2013
Sadie Holzman Diaz (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Sarah C. Chandrika (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Zachary L. Rowen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 50 of 250

Plaintiff Sreenivasarao Raparthy

represented by Daniel D. Adams (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED
Andrew Richard Lugerner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Benton J. Campbell (See above for address) TERMINATED: 04/02/2014 PRO HAC VICE
Christopher R. Harris (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Elizabeth C. Rowland (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric Marshall Broad (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric L. Taffet (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Grant F. Wahlquist (See above for address) TERMINATED: 03/08/2017 PRO HAC VICE ATTORNEY TO BE NOTICED
H. Gregory Baker (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jacob A. Walker (See above for address) TERMINATED: 09/09/2015 PRO HAC VICE
Jennifer Greenberg (See above for address)

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 51 of 250

TERMINATED: 12/10/2013 PRO HAC VICE

Jessica D. Rostoker (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Katelyn M. Beaudette (See above for address) TERMINATED: 11/30/2016 PRO HAC VICE

Kirk A. Wilkinson (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Matthew S. Salerno (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Michael A. Romey (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Michael R. Walsh (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Miles N. Ruthberg (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Rebekah L. Soule (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Sadie Holzman Diaz (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Sarah C. Chandrika (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Zachary L. Rowen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Plaintiff

represented by

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 52 of 250

Mookaparambil Itty Raveendranathan

Daniel D. Adams (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Andrew Richard Lugerner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Benton J. Campbell (See above for address) TERMINATED: 04/02/2014 PRO HAC VICE

Christopher R. Harris (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Elizabeth C. Rowland (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Eric Marshall Broad (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Eric L. Taffet (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

H. Gregory Baker (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE

Jacob A. Walker (See above for address) TERMINATED: 09/09/2015 PRO HAC VICE

Jennifer Greenberg (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE

Jessica D. Rostoker (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 53 of 250

Kirk A. Wilkinson (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Michael A. Romey (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Michael R. Walsh (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Miles N. Ruthberg (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Rebekah L. Soule (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Renee E. Plexousakis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Sadie Holzman Diaz (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Sarah C. Chandrika (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Zachary L. Rowen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Plaintiff Balwinder Singh

represented by Daniel D. Adams (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 54 of 250
Andrew Richard Lugerner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Benton J. Campbell (See above for address) TERMINATED: 04/02/2014 PRO HAC VICE
Christopher R. Harris (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Elizabeth C. Rowland (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric Marshall Broad (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric L. Taffet (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Grant F. Wahlquist (See above for address) TERMINATED: 03/08/2017 PRO HAC VICE ATTORNEY TO BE NOTICED
H. Gregory Baker (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jacob A. Walker (See above for address) TERMINATED: 09/09/2015 PRO HAC VICE
Jennifer Greenberg (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jessica D. Rostoker (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Katelyn M. Beaudette (See above for address) TERMINATED: 11/30/2016 PRO HAC VICE
Kirk A. Wilkinson (See above for address) PRO HAC VICE

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 55 of 250

ATTORNEY TO BE NOTICED

Matthew S. Salerno (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Michael A. Romey (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Michael R. Walsh (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Miles N. Ruthberg (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Rebekah L. Soule (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Renee E. Plexousakis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Sadie Holzman Diaz (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Sarah C. Chandrika (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Zachary L. Rowen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Plaintiff Ranjit Singh

represented by Daniel D. Adams (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 56 of 250
(See above for address) ATTORNEY TO BE NOTICED
Andrew Richard Lugerner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Benton J. Campbell (See above for address) TERMINATED: 04/02/2014 PRO HAC VICE
Christopher R. Harris (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Elizabeth C. Rowland (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric Marshall Broad (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric L. Taffet (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Grant F. Wahlquist (See above for address) TERMINATED: 03/08/2017 PRO HAC VICE ATTORNEY TO BE NOTICED
H. Gregory Baker (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jacob A. Walker (See above for address) TERMINATED: 09/09/2015 PRO HAC VICE
Jennifer Greenberg (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jessica D. Rostoker (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Katelyn M. Beaudette (See above for address) TERMINATED: 11/30/2016 PRO HAC VICE
Kirk A. Wilkinson

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 57 of 250

(See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Matthew S. Salerno (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Michael A. Romey (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Michael R. Walsh (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Miles N. Ruthberg (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Rebekah L. Soule (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Renee E. Plexousakis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Sadie Holzman Diaz (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Sarah C. Chandrika (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Zachary L. Rowen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Plaintiff
Shanmugam Subramanian

represented by Daniel D. Adams (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 58 of 250
A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED
Andrew Richard Lugerner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Benton J. Campbell (See above for address) TERMINATED: 04/02/2014 PRO HAC VICE
Christopher R. Harris (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Elizabeth C. Rowland (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric Marshall Broad (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric L. Taffet (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Grant F. Wahlquist (See above for address) TERMINATED: 03/08/2017 PRO HAC VICE ATTORNEY TO BE NOTICED
H. Gregory Baker (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jacob A. Walker (See above for address) TERMINATED: 09/09/2015 PRO HAC VICE
Jennifer Greenberg (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jessica D. Rostoker (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Katelyn M. Beaudette (See above for address) TERMINATED: 11/30/2016 PRO HAC VICE

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 59 of 250

Plaintiff Ninan John Tharakan

Kirk A. Wilkinson (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Matthew S. Salerno (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael A. Romey (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael R. Walsh (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Miles N. Ruthberg (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Rebekah L. Soule (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Renee E. Plexousakis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Robert B. McDuff (See above for address) TERMINATED: 12/27/2013
Sadie Holzman Diaz (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Sarah C. Chandrika (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Zachary L. Rowen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
represented by Daniel D. Adams (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Meredith S. Grabill (See above for address)

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 60 of 250
LEAD ATTORNEY ATTORNEY TO BE NOTICED
A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED
Andrew Richard Lugerner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Benton J. Campbell (See above for address) TERMINATED: 04/02/2014 PRO HAC VICE
Christopher R. Harris (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Elizabeth C. Rowland (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric Marshall Broad (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric L. Taffet (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Grant F. Wahlquist (See above for address) TERMINATED: 03/08/2017 PRO HAC VICE ATTORNEY TO BE NOTICED
H. Gregory Baker (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jacob A. Walker (See above for address) TERMINATED: 09/09/2015 PRO HAC VICE
Jennifer Greenberg (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jessica D. Rostoker (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Katelyn M. Beaudette (See above for address)

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 61 of 250

TERMINATED: 11/30/2016 PRO HAC VICE

Kirk A. Wilkinson (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Matthew S. Salerno (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Michael A. Romey (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Michael R. Walsh (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Miles N. Ruthberg (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Rebekah L. Soule (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Renee E. Plexousakis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Sadie Holzman Diaz (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Sarah C. Chandrika (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Zachary L. Rowen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Plaintiff
George Pulikkeparambil Varghese

represented by Daniel D. Adams (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 62 of 250
Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED
Andrew Richard Lugerner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Benton J. Campbell (See above for address) TERMINATED: 04/02/2014 PRO HAC VICE
Christopher R. Harris (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Elizabeth C. Rowland (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric Marshall Broad (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric L. Taffet (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Grant F. Wahlquist (See above for address) TERMINATED: 03/08/2017 PRO HAC VICE ATTORNEY TO BE NOTICED
H. Gregory Baker (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jacob A. Walker (See above for address) TERMINATED: 09/09/2015 PRO HAC VICE
Jennifer Greenberg (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jessica D. Rostoker (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 63 of 250

Katelyn M. Beaudette (See above for address) TERMINATED: 11/30/2016 PRO HAC VICE

Kirk A. Wilkinson (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Matthew S. Salerno (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Michael A. Romey (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Michael R. Walsh (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Miles N. Ruthberg (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Rebekah L. Soule (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Renee E. Plexousakis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Sadie Holzman Diaz (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Sarah C. Chandrika (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Zachary L. Rowen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Plaintiff
Benny Kattukariyil Varkey

represented by Daniel D. Adams (See above for address) LEAD ATTORNEY PRO HAC VICE

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 64 of 250
ATTORNEY TO BE NOTICED
Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED
Andrew Richard Lugerner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Benton J. Campbell (See above for address) TERMINATED: 04/02/2014 PRO HAC VICE
Christopher R. Harris (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Elizabeth C. Rowland (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric Marshall Broad (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric L. Taffet (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Grant F. Wahlquist (See above for address) TERMINATED: 03/08/2017 PRO HAC VICE ATTORNEY TO BE NOTICED
H. Gregory Baker (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jacob A. Walker (See above for address) TERMINATED: 09/09/2015 PRO HAC VICE
Jennifer Greenberg (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jessica D. Rostoker (See above for address) PRO HAC VICE

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 65 of 250

ATTORNEY TO BE NOTICED

Katelyn M. Beaudette (See above for address) TERMINATED: 11/30/2016 PRO HAC VICE

Kirk A. Wilkinson (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Matthew S. Salerno (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Michael A. Romey (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Michael R. Walsh (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Miles N. Ruthberg (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Rebekah L. Soule (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Renee E. Plexousakis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Sadie Holzman Diaz (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Sarah C. Chandrika (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Zachary L. Rowen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Plaintiff Shahi Vijayan

represented by Daniel D. Adams (See above for address)

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 66 of 250
LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED
Andrew Richard Lugerner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Benton J. Campbell (See above for address) TERMINATED: 04/02/2014 PRO HAC VICE
Christopher R. Harris (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Elizabeth C. Rowland (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric Marshall Broad (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric L. Taffet (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Grant F. Wahlquist (See above for address) TERMINATED: 03/08/2017 PRO HAC VICE ATTORNEY TO BE NOTICED
H. Gregory Baker (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jacob A. Walker (See above for address) TERMINATED: 09/09/2015 PRO HAC VICE
Jennifer Greenberg (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jessica D. Rostoker

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 67 of 250
(See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Katelyn M. Beaudette (See above for address) TERMINATED: 11/30/2016 PRO HAC VICE
Kirk A. Wilkinson (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Matthew S. Salerno (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael A. Romey (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael R. Walsh (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Miles N. Ruthberg (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Rebekah L. Soule (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Renee E. Plexousakis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Robert B. McDuff (See above for address) TERMINATED: 12/27/2013
Sadie Holzman Diaz (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Sarah C. Chandrika (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Zachary L. Rowen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Plaintiff

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 68 of 250

John Yohannan

represented by Daniel D. Adams (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Andrew Richard Lugerner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Benton J. Campbell (See above for address) TERMINATED: 04/02/2014 PRO HAC VICE

Christopher R. Harris (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Elizabeth C. Rowland (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Eric Marshall Broad (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Eric L. Taffet (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Grant F. Wahlquist (See above for address) TERMINATED: 03/08/2017 PRO HAC VICE ATTORNEY TO BE NOTICED

H. Gregory Baker (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE

Jacob A. Walker (See above for address) TERMINATED: 09/09/2015 PRO HAC VICE

Jennifer Greenberg (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 69 of 250
Jessica D. Rostoker (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Katelyn M. Beaudette (See above for address) TERMINATED: 11/30/2016 PRO HAC VICE
Kirk A. Wilkinson (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Matthew S. Salerno (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael A. Romey (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael R. Walsh (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Miles N. Ruthberg (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Rebekah L. Soule (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Renee E. Plexousakis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Robert B. McDuff (See above for address) TERMINATED: 12/27/2013
Sadie Holzman Diaz (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Sarah C. Chandrika (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Zachary L. Rowen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 70 of 250

Plaintiff
Kuliyanickal Paily Varghese Estate of

represented by Daniel D. Adams (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED
Andrew Richard Lugerner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Benton J. Campbell (See above for address) TERMINATED: 04/02/2014 PRO HAC VICE
Christopher R. Harris (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Elizabeth C. Rowland (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric Marshall Broad (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric L. Taffet (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Grant F. Wahlquist (See above for address) TERMINATED: 03/08/2017 PRO HAC VICE ATTORNEY TO BE NOTICED
H. Gregory Baker (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jacob A. Walker (See above for address) TERMINATED: 09/09/2015 PRO HAC VICE
Jennifer Greenberg (See above for address)

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 71 of 250
TERMINATED: 12/10/2013 PRO HAC VICE
Jessica D. Rostoker (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Katelyn M. Beaudette (See above for address) TERMINATED: 11/30/2016 PRO HAC VICE
Kirk A. Wilkinson (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Matthew S. Salerno (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael A. Romey (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael R. Walsh (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Miles N. Ruthberg (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Rebekah L. Soule (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Renee E. Plexousakis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Robert B. McDuff (See above for address) TERMINATED: 12/27/2013
Sadie Holzman Diaz (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Sarah C. Chandrika (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Zachary L. Rowen (See above for address) PRO HAC VICE

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 72 of 250

ATTORNEY TO BE NOTICED

Plaintiff Eldose Isac

represented by Daniel D. Adams (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Andrew Richard Lugerner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Benton J. Campbell (See above for address) TERMINATED: 04/02/2014 PRO HAC VICE

Christopher R. Harris (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Elizabeth C. Rowland (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Eric Marshall Broad (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Eric L. Taffet (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Grant F. Wahlquist (See above for address) TERMINATED: 03/08/2017 PRO HAC VICE ATTORNEY TO BE NOTICED

H. Gregory Baker (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE

Jacob A. Walker (See above for address) TERMINATED: 09/09/2015 PRO HAC VICE

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 73 of 250
Jennifer Greenberg (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jessica D. Rostoker (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Katelyn M. Beaudette (See above for address) TERMINATED: 11/30/2016 PRO HAC VICE
Kirk A. Wilkinson (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Matthew S. Salerno (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael A. Romey (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael R. Walsh (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Miles N. Ruthberg (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Rebekah L. Soule (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Renee E. Plexousakis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Robert B. McDuff (See above for address) TERMINATED: 12/27/2013
Sadie Holzman Diaz (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Sarah C. Chandrika (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Zachary L. Rowen

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 74 of 250

(See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Plaintiff Savinder Singh

represented by Daniel D. Adams (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Andrew Richard Lugerner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Benton J. Campbell (See above for address) TERMINATED: 04/02/2014 PRO HAC VICE

Christopher R. Harris (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Elizabeth C. Rowland (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Eric Marshall Broad (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Eric L. Taffet (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Grant F. Wahlquist (See above for address) TERMINATED: 03/08/2017 PRO HAC VICE ATTORNEY TO BE NOTICED

H. Gregory Baker (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE

Jacob A. Walker (See above for address) TERMINATED: 09/09/2015

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 75 of 250
PRO HAC VICE
Jennifer Greenberg (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jessica D. Rostoker (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Katelyn M. Beaudette (See above for address) TERMINATED: 11/30/2016 PRO HAC VICE
Kirk A. Wilkinson (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Matthew S. Salerno (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael A. Romey (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael R. Walsh (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Miles N. Ruthberg (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Rebekah L. Soule (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Renee E. Plexousakis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Robert B. McDuff (See above for address) TERMINATED: 12/27/2013
Sadie Holzman Diaz (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Sarah C. Chandrika (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 76 of 250

Plaintiff Thansilas Joseph

Zachary L. Rowen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
represented by Daniel D. Adams (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED
Andrew Richard Lugerner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Benton J. Campbell (See above for address) TERMINATED: 04/02/2014 PRO HAC VICE
Christopher R. Harris (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Elizabeth C. Rowland (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric Marshall Broad (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric L. Taffet (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Grant F. Wahlquist (See above for address) TERMINATED: 03/08/2017 PRO HAC VICE ATTORNEY TO BE NOTICED
H. Gregory Baker (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jacob A. Walker

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 77 of 250
(See above for address) TERMINATED: 09/09/2015 PRO HAC VICE
Jennifer Greenberg (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jessica D. Rostoker (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Katelyn M. Beaudette (See above for address) TERMINATED: 11/30/2016 PRO HAC VICE
Kirk A. Wilkinson (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Matthew S. Salerno (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael A. Romey (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael R. Walsh (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Miles N. Ruthberg (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Rebekah L. Soule (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Renee E. Plexousakis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Robert B. McDuff (See above for address) TERMINATED: 12/27/2013
Sadie Holzman Diaz (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Sarah C. Chandrika (See above for address)

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 78 of 250

PRO HAC VICE ATTORNEY TO BE NOTICED

Zachary L. Rowen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Plaintiff
Varghese Varkey Abraham

represented by Daniel D. Adams (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Andrew Richard Lugerner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Benton J. Campbell (See above for address) TERMINATED: 04/02/2014 PRO HAC VICE

Christopher R. Harris (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Elizabeth C. Rowland (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Eric Marshall Broad (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Eric L. Taffet (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Grant F. Wahlquist (See above for address) TERMINATED: 03/08/2017 PRO HAC VICE ATTORNEY TO BE NOTICED

H. Gregory Baker (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 79 of 250
Jacob A. Walker (See above for address) TERMINATED: 09/09/2015 PRO HAC VICE
Jennifer Greenberg (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jessica D. Rostoker (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Katelyn M. Beaudette (See above for address) TERMINATED: 11/30/2016 PRO HAC VICE
Kirk A. Wilkinson (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Matthew S. Salerno (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael A. Romey (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael R. Walsh (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Miles N. Ruthberg (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Rebekah L. Soule (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Renee E. Plexousakis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Robert B. McDuff (See above for address) TERMINATED: 12/27/2013
Sadie Holzman Diaz (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 80 of 250

Sarah C. Chandrika (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Zachary L. Rowen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Plaintiff Subhashithan Bahuleyan

represented by Daniel D. Adams (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Andrew Richard Lugerner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Benton J. Campbell (See above for address) TERMINATED: 04/02/2014 PRO HAC VICE

Christopher R. Harris (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Elizabeth C. Rowland (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Eric Marshall Broad (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Eric L. Taffet (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Grant F. Wahlquist (See above for address) TERMINATED: 03/08/2017 PRO HAC VICE ATTORNEY TO BE NOTICED

H. Gregory Baker (See above for address)

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 81 of 250
TERMINATED: 12/10/2013 PRO HAC VICE
Jacob A. Walker (See above for address) TERMINATED: 09/09/2015 PRO HAC VICE
Jennifer Greenberg (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jessica D. Rostoker (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Katelyn M. Beaudette (See above for address) TERMINATED: 11/30/2016 PRO HAC VICE
Kirk A. Wilkinson (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Matthew S. Salerno (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael A. Romey (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael R. Walsh (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Miles N. Ruthberg (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Rebekah L. Soule (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Renee E. Plexousakis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Robert B. McDuff (See above for address) TERMINATED: 12/27/2013
Sadie Holzman Diaz (See above for address) PRO HAC VICE

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 82 of 250

ATTORNEY TO BE NOTICED

Sarah C. Chandrika (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Zachary L. Rowen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Plaintiff
Thenooran Kumaran Unnikrishnan

represented by Daniel D. Adams (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Benton J. Campbell (See above for address) TERMINATED: 04/02/2014 PRO HAC VICE

Christopher R. Harris (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Elizabeth C. Rowland (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Eric Marshall Broad (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Eric L. Taffet (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Grant F. Wahlquist (See above for address) TERMINATED: 03/08/2017 PRO HAC VICE ATTORNEY TO BE NOTICED

H. Gregory Baker (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 83 of 250
Jacob A. Walker (See above for address) TERMINATED: 09/09/2015 PRO HAC VICE
Jennifer Greenberg (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jessica D. Rostoker (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Katelyn M. Beaudette (See above for address) TERMINATED: 11/30/2016 PRO HAC VICE
Kirk A. Wilkinson (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Matthew S. Salerno (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael A. Romey (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael R. Walsh (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Miles N. Ruthberg (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Rebekah L. Soule (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Renee E. Plexousakis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Robert B. McDuff (See above for address) TERMINATED: 12/27/2013
Sadie Holzman Diaz (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Sarah C. Chandrika

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 84 of 250

(See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Zachary L. Rowen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Plaintiff
Kulath Somanathan Kalayam

represented by Daniel D. Adams (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Andrew Richard Lugerner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Benton J. Campbell (See above for address) TERMINATED: 04/02/2014 PRO HAC VICE

Christopher R. Harris (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Elizabeth C. Rowland (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Eric Marshall Broad (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Eric L. Taffet (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Grant F. Wahlquist (See above for address) TERMINATED: 03/08/2017 PRO HAC VICE ATTORNEY TO BE NOTICED

H. Gregory Baker (See above for address) TERMINATED: 12/10/2013

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 85 of 250
PRO HAC VICE
Jacob A. Walker (See above for address) TERMINATED: 09/09/2015 PRO HAC VICE
Jennifer Greenberg (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jessica D. Rostoker (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Katelyn M. Beaudette (See above for address) TERMINATED: 11/30/2016 PRO HAC VICE
Kirk A. Wilkinson (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Matthew S. Salerno (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael A. Romey (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael R. Walsh (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Miles N. Ruthberg (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Rebekah L. Soule (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Renee E. Plexousakis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Robert B. McDuff (See above for address) TERMINATED: 12/27/2013
Sadie Holzman Diaz (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 86 of 250

Plaintiff
Praveen Kulathum Muriyi Gopalakrishnan

Sarah C. Chandrika (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Zachary L. Rowen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
represented by Daniel D. Adams (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED
Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED
Andrew Richard Lugerner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Benton J. Campbell (See above for address) TERMINATED: 04/02/2014 PRO HAC VICE
Christopher R. Harris (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Elizabeth C. Rowland (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric Marshall Broad (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric L. Taffet (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Grant F. Wahlquist (See above for address) TERMINATED: 03/08/2017 PRO HAC VICE ATTORNEY TO BE NOTICED
H. Gregory Baker

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 87 of 250
(See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jacob A. Walker (See above for address) TERMINATED: 09/09/2015 PRO HAC VICE
Jennifer Greenberg (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jessica D. Rostoker (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Katelyn M. Beaudette (See above for address) TERMINATED: 11/30/2016 PRO HAC VICE
Kirk A. Wilkinson (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Matthew S. Salerno (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael A. Romey (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael R. Walsh (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Miles N. Ruthberg (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Rebekah L. Soule (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Renee E. Plexousakis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Robert B. McDuff (See above for address) TERMINATED: 12/27/2013
Sadie Holzman Diaz (See above for address)

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 88 of 250

PRO HAC VICE ATTORNEY TO BE NOTICED

Sarah C. Chandrika (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Zachary L. Rowen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Plaintiff
Moni Panikulangara Thomas

represented by Daniel D. Adams (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Andrew Richard Lugerner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Benton J. Campbell (See above for address) TERMINATED: 04/02/2014 PRO HAC VICE

Christopher R. Harris (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Elizabeth C. Rowland (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Eric Marshall Broad (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Eric L. Taffet (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Grant F. Wahlquist (See above for address) TERMINATED: 03/08/2017 PRO HAC VICE ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 89 of 250
H. Gregory Baker (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jacob A. Walker (See above for address) TERMINATED: 09/09/2015 PRO HAC VICE
Jennifer Greenberg (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jessica D. Rostoker (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Katelyn M. Beaudette (See above for address) TERMINATED: 11/30/2016 PRO HAC VICE
Kirk A. Wilkinson (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Matthew S. Salerno (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael A. Romey (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael R. Walsh (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Miles N. Ruthberg (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Rebekah L. Soule (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Renee E. Plexousakis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 90 of 250

Sadie Holzman Diaz (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Sarah C. Chandrika (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Zachary L. Rowen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Plaintiff
Kittayi Sunil Kumar Therattil

represented by Daniel D. Adams (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Andrew Richard Lugerner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Benton J. Campbell (See above for address) TERMINATED: 04/02/2014 PRO HAC VICE

Christopher R. Harris (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Elizabeth C. Rowland (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Eric Marshall Broad (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Eric L. Taffet (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Grant F. Wahlquist (See above for address) TERMINATED: 03/08/2017

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 91 of 250
PRO HAC VICE ATTORNEY TO BE NOTICED
H. Gregory Baker (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jacob A. Walker (See above for address) TERMINATED: 09/09/2015 PRO HAC VICE
Jennifer Greenberg (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jessica D. Rostoker (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Katelyn M. Beaudette (See above for address) TERMINATED: 11/30/2016 PRO HAC VICE
Kirk A. Wilkinson (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Matthew S. Salerno (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael A. Romey (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael R. Walsh (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Miles N. Ruthberg (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Rebekah L. Soule (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Renee E. Plexousakis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Robert B. McDuff (See above for address)

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 92 of 250

TERMINATED: 12/27/2013

Sadie Holzman Diaz (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Sarah C. Chandrika (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Zachary L. Rowen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Plaintiff
Benny Chittilappilly Vareed

represented by Daniel D. Adams (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Andrew Richard Lugerner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Benton J. Campbell (See above for address) TERMINATED: 04/02/2014 PRO HAC VICE

Christopher R. Harris (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Elizabeth C. Rowland (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Eric Marshall Broad (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Eric L. Taffet (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Grant F. Wahlquist

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 93 of 250
(See above for address) TERMINATED: 03/08/2017 PRO HAC VICE ATTORNEY TO BE NOTICED
H. Gregory Baker (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jacob A. Walker (See above for address) TERMINATED: 09/09/2015 PRO HAC VICE
Jennifer Greenberg (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jessica D. Rostoker (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Katelyn M. Beaudette (See above for address) TERMINATED: 11/30/2016 PRO HAC VICE
Kirk A. Wilkinson (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Matthew S. Salerno (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael A. Romey (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael R. Walsh (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Miles N. Ruthberg (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Rebekah L. Soule (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Renee E. Plexousakis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 94 of 250

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Sadie Holzman Diaz (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Sarah C. Chandrika (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Zachary L. Rowen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Plaintiff Nibu Raju

represented by Daniel D. Adams (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Andrew Richard Lugerner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Benton J. Campbell (See above for address) TERMINATED: 04/02/2014 PRO HAC VICE

Christopher R. Harris (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Elizabeth C. Rowland (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Eric Marshall Broad (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Eric L. Taffet (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 95 of 250
Grant F. Wahlquist (See above for address) TERMINATED: 03/08/2017 PRO HAC VICE ATTORNEY TO BE NOTICED
H. Gregory Baker (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jacob A. Walker (See above for address) TERMINATED: 09/09/2015 PRO HAC VICE
Jennifer Greenberg (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jessica D. Rostoker (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Katelyn M. Beaudette (See above for address) TERMINATED: 11/30/2016 PRO HAC VICE
Kirk A. Wilkinson (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Matthew S. Salerno (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael A. Romey (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael R. Walsh (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Miles N. Ruthberg (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Rebekah L. Soule (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Renee E. Plexousakis (See above for address) PRO HAC VICE

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 96 of 250

ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Sadie Holzman Diaz (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Sarah C. Chandrika (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Zachary L. Rowen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Plaintiff
Bhaskaran Sreedharan Kutty

represented by Daniel D. Adams (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Andrew Richard Lugerner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Benton J. Campbell (See above for address) TERMINATED: 04/02/2014 PRO HAC VICE

Christopher R. Harris (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Elizabeth C. Rowland (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Eric Marshall Broad (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Eric L. Taffet (See above for address)

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 97 of 250
PRO HAC VICE ATTORNEY TO BE NOTICED
Grant F. Wahlquist (See above for address) TERMINATED: 03/08/2017 PRO HAC VICE ATTORNEY TO BE NOTICED
H. Gregory Baker (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jacob A. Walker (See above for address) TERMINATED: 09/09/2015 PRO HAC VICE
Jennifer Greenberg (See above for address) TERMINATED: 12/10/2013 PRO HAC VICE
Jessica D. Rostoker (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Katelyn M. Beaudette (See above for address) TERMINATED: 11/30/2016 PRO HAC VICE
Kirk A. Wilkinson (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Matthew S. Salerno (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael A. Romey (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael R. Walsh (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Miles N. Ruthberg (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Rebekah L. Soule (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Renee E. Plexousakis

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 98 of 250
(See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Robert B. McDuff (See above for address) TERMINATED: 12/27/2013
Sadie Holzman Diaz (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Sarah C. Chandrika (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Zachary L. Rowen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

V.
Consol Plaintiff
Varghese Kurisinkal Devassy (13−6221)

represented by Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED
Andrew Case Manatt, Phelps & Phillips, LLP (New York) 7 Times Square New York, NY 10036 212−790−4501 Email: acase@manatt.com PRO HAC VICE ATTORNEY TO BE NOTICED
Christopher A. Rheinheimer Manatt, Phelps & Phillips (San Francisco) One Embarcadero Center 30th Floor San Francisco, CA 94111 415−291−7468 Email: crheinheimer@manatt.com PRO HAC VICE ATTORNEY TO BE NOTICED
Daniele J Capasso Manatt, Phelps & Phillips, LLP 700 12th Street NW Washington, DC 20005 202−585−6500 Email: dcapasso@manatt.com PRO HAC VICE ATTORNEY TO BE NOTICED
Eric B. Chen

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 99 of 250
Manatt, Phelps & Phillips, LLP (Los Angeles) 11355 W. Olympic Blvd. Los Angeles, CA 90064 310−312−4167 Email: echen@manatt.com PRO HAC VICE ATTORNEY TO BE NOTICED
Jeremy R. Lacks Manatt, Phelps & Phillips, LLP (New York) 7 Times Square New York, NY 10036 212−790−4500 Fax: 212−790−4545 Email: jlacks@manatt.com PRO HAC VICE ATTORNEY TO BE NOTICED
Matthew P. Kanny Manatt, Phelps & Phillips, LLP 11355 W. Olympic Blvd. Los Angeles, CA 90064 310−312−4000 Email: mkanny@manatt.com PRO HAC VICE ATTORNEY TO BE NOTICED
Michael Bhargava MANATT PHELPS & PHILLIPS LLP − Washington 700 12th Street NW Suite 1100 Washington, DC 20006 202/585−6500 Fax: 202/585−6600 Email: mbhargava@manatt.com PRO HAC VICE ATTORNEY TO BE NOTICED
Robert Fabrikant MANATT PHELPS & PHILLIPS LLP − Washington 700 12th Street NW Suite 1100 Washington, DC 20006 202/585−6500 Fax: 202/585−6600 Email: rfabrikant@manatt.com PRO HAC VICE ATTORNEY TO BE NOTICED
Robert B. McDuff (See above for address) TERMINATED: 12/27/2013
Ronald G. Blum Manatt, Phelps & Phillips, LLP (New York) 7 Times Square New York, NY 10036 212−790−4500 Email: rblum@manatt.com PRO HAC VICE ATTORNEY TO BE NOTICED
Ryan J. Alshak Manatt, Phelps & Phillips, LLP (Los Angeles) 11355 W. Olympic Blvd.

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 100 of 250

Los Angeles, CA 90064 310−312−4332 Email: ralshak@manatt.com PRO HAC VICE ATTORNEY TO BE NOTICED

Stephen T. Raptis Manatt, Phelps & Phillips, LLP (Washington) 700 12th Street NW Washington, DC 20005 202/585−6550 Fax: 202/585−6600 Email: sraptis@manatt.com PRO HAC VICE ATTORNEY TO BE NOTICED

Consol Plaintiff
George Chacko Edavazhickal (13−6221)

represented by Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Christopher A. Rheinheimer (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Eric B. Chen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Jeremy R. Lacks (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Matthew P. Kanny (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Michael Bhargava (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert Fabrikant (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Ronald G. Blum (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 101 of 250

Consol Plaintiff
Ampattu Varughese Mathew (13−6221)

Ryan J. Alshak (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Stephen T. Raptis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
represented by Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED
Christopher A. Rheinheimer (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric B. Chen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Jeremy R. Lacks (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Matthew P. Kanny (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael Bhargava (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Robert Fabrikant (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Robert B. McDuff (See above for address) TERMINATED: 12/27/2013
Ronald G. Blum (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Ryan J. Alshak (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 102 of 250

Consol Plaintiff
Anthony Sajan Oottuparambil Michael (13−6221)

Stephen T. Raptis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
represented by Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED
Christopher A. Rheinheimer (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric B. Chen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Jeremy R. Lacks (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Matthew P. Kanny (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael Bhargava (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Robert Fabrikant (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Robert B. McDuff (See above for address) TERMINATED: 12/27/2013
Ronald G. Blum (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Ryan J. Alshak (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Stephen T. Raptis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 103 of 250

Consol Plaintiff
Sivan Raghavan (13−6221)

represented by Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Christopher A. Rheinheimer (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Eric B. Chen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Jeremy R. Lacks (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Matthew P. Kanny (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Michael Bhargava (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert Fabrikant (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Ronald G. Blum (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Ryan J. Alshak (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Stephen T. Raptis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Consol Plaintiff
Vijayanair Sankarapillai (13−6221)

represented by Meredith S. Grabill (See above for address) LEAD ATTORNEY

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 104 of 250

ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Christopher A. Rheinheimer (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Eric B. Chen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Jeremy R. Lacks (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Matthew P. Kanny (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Michael Bhargava (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert Fabrikant (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Ronald G. Blum (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Ryan J. Alshak (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Stephen T. Raptis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Consol Plaintiff
Anil Scaria (13−6221)

represented by Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 105 of 250

Consol Plaintiff
Mandeep Singh (13−6221)

Christopher A. Rheinheimer (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric B. Chen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Jeremy R. Lacks (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Matthew P. Kanny (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael Bhargava (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Robert Fabrikant (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Robert B. McDuff (See above for address) TERMINATED: 12/27/2013
Ronald G. Blum (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Ryan J. Alshak (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Stephen T. Raptis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
represented by Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED
Christopher A. Rheinheimer (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 106 of 250

Consol Plaintiff
John Malakaran Thomas (13−6221)

Eric B. Chen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Jeremy R. Lacks (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Matthew P. Kanny (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael Bhargava (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Robert Fabrikant (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Robert B. McDuff (See above for address) TERMINATED: 12/27/2013
Ronald G. Blum (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Ryan J. Alshak (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Stephen T. Raptis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
represented by Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED
Christopher A. Rheinheimer (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric B. Chen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 107 of 250

Consol Plaintiff
Saju Christy Vallarian (13−6221)

Jeremy R. Lacks (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Matthew P. Kanny (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael Bhargava (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Robert Fabrikant (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Robert B. McDuff (See above for address) TERMINATED: 12/27/2013
Ronald G. Blum (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Ryan J. Alshak (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Stephen T. Raptis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
represented by Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED
Christopher A. Rheinheimer (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric B. Chen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Jeremy R. Lacks (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 108 of 250

Consol Plaintiff
Isaac Wilson Vazhikudilil (13−6221)

Matthew P. Kanny (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael Bhargava (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Robert Fabrikant (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Robert B. McDuff (See above for address) TERMINATED: 12/27/2013
Ronald G. Blum (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Ryan J. Alshak (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Stephen T. Raptis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
represented by Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED
Christopher A. Rheinheimer (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric B. Chen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Jeremy R. Lacks (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Matthew P. Kanny (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 109 of 250

Consol Plaintiff
Benny Yohannan (13−6221)

Michael Bhargava (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Robert Fabrikant (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Robert B. McDuff (See above for address) TERMINATED: 12/27/2013
Ronald G. Blum (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Ryan J. Alshak (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Stephen T. Raptis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
represented by Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED
Christopher A. Rheinheimer (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric B. Chen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Jeremy R. Lacks (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Matthew P. Kanny (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael Bhargava (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 110 of 250

Consol Plaintiff
Prasad Kunju Kunju (13−6221)

Robert Fabrikant (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Robert B. McDuff (See above for address) TERMINATED: 12/27/2013
Ronald G. Blum (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Ryan J. Alshak (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Stephen T. Raptis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
represented by Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED
Christopher A. Rheinheimer (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Eric B. Chen (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Jeremy R. Lacks (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Matthew P. Kanny (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael Bhargava (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Robert Fabrikant (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 111 of 250

Consol Plaintiff
Sabu Puthukkuttumel Veede Krishnakutty (13−6220)

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013
Ronald G. Blum (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Ryan J. Alshak (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Stephen T. Raptis (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
represented by Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED
Asra A. Chatham McDermott, Will & Emery, LLP (Miami) 333 Avenue of the Americas Suite 4500 Miami, FL 33131−2184 305−358−3500 Email: achatham@mwe.com PRO HAC VICE ATTORNEY TO BE NOTICED
John C. Low− PHV MCDERMOTT, WILL & EMERY, LLP − Houston 1000 Louisiana Street, Suite 3900 Houston, TX 77002 713/653−1781 Fax: 713/739−7592 Email: jlow@mwe.com TERMINATED: 04/04/2017 PRO HAC VICE
Justin P. Aiello McDermott, Will & Emery, LLP (Miami) 333 Avenue of the Americas Suite 4500 Miami, FL 33131−2184 305−358−3500 Email: jaiello@mwe.com PRO HAC VICE ATTORNEY TO BE NOTICED
Justin B. Uhlemann MCDERMOTT, WILL & EMERY, LLP − Miami 333 SE 2nd Avenue, Suite 4500 Miami, FL 33131−2184

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 112 of 250

305/347−6534 Fax: 305/347−6500 Email: juhlemann@mwe.com TERMINATED: 12/27/2013 PRO HAC VICE

Marissa C. Krumm McDermott, Will & Emery, LLP (Miami) 333 Avenue of the Americas Suite 4500 Miami, FL 33131−2184 305−358−3500 Email: mkrumm@mwe.com PRO HAC VICE ATTORNEY TO BE NOTICED

Mark H. Churchill McDermott, Will & Emery LLP (Washington) 500 North Capitol Street, N.W. Washington, DC 20001−1531 202−756−8000 Email: mchurchill@mwe.com PRO HAC VICE ATTORNEY TO BE NOTICED

Robert M. Kline McDermott, Will & Emery, LLP (Miami) 333 Avenue of the Americas Suite 4500 Miami, FL 33131−2184 305−358−3500 Email: rkline@mwe.com PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Scott W. Clark MCDERMOTT, WILL & EMERY, LLP − Houston 1000 Louisiana Street, Suite 3900 Houston, TX 77002 713/653−1745 Fax: 713/739−7592 Email: sclark@mwe.com TERMINATED: 12/02/2014 PRO HAC VICE ATTORNEY TO BE NOTICED

Steven G. Spears MCDERMOTT, WILL & EMERY, LLP − Houston 1000 Louisiana Street, Suite 3900 Houston, TX 77002 713/653−1784 Fax: 713/739−7592 Email: sspears@mwe.com PRO HAC VICE ATTORNEY TO BE NOTICED

Consol Plaintiff
Thampy Putham Parambil Edicula (13−6220)

represented by Meredith S. Grabill (See above for address) LEAD ATTORNEY

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 113 of 250

ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Asra A. Chatham (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

John C. Low− PHV (See above for address) TERMINATED: 04/04/2017 PRO HAC VICE

Justin P. Aiello (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Justin B. Uhlemann (See above for address) TERMINATED: 12/27/2013 PRO HAC VICE

Marissa C. Krumm (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Mark H. Churchill (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert M. Kline (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Scott W. Clark (See above for address) TERMINATED: 12/02/2014 PRO HAC VICE ATTORNEY TO BE NOTICED

Steven G. Spears (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Consol Plaintiff
George Paily Paulose Chakkiyattil (13−6219)

represented by Eben P. Colby Skadden, Arps, Slate, Meagher & Flom, LLP 500 Boyslton Street Boston, MA 02116 617/573−4800 Fax: 617/573−4822 Email: eben.colby@skadden.com

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 114 of 250

LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Jacob A. Walker (See above for address) TERMINATED: 09/09/2015 PRO HAC VICE

Peter Simshauser Skadden, Arps, Slate, Meagher & Flom, LLP 500 Boyslton Street Boston, MA 02116 617/573−4800 Fax: 617/573−4822 Email: peter.simshauser@skadden.com PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Consol Plaintiff
Chandrasekhara Pillai Rajesh Chemmanappilly (13−6219)

represented by Eben P. Colby (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Peter Simshauser (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Consol Plaintiff
Sukumar Moses Dokka (13−6219)

represented by Eben P. Colby (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 115 of 250

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Peter Simshauser (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Consol Plaintiff
Roy Punakkattu George (13−6219)

represented by Eben P. Colby (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Peter Simshauser (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Consol Plaintiff
Radhakrishnan Kakkathiruthi (13−6219)

represented by Eben P. Colby (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Peter Simshauser (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 116 of 250

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Consol Plaintiff
John Abraham Kalampukatt (13−6219)

represented by Eben P. Colby (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Peter Simshauser (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Consol Plaintiff
Thomas Baby Madakkameprathu (13−6219)

represented by Eben P. Colby (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Peter Simshauser (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Consol Plaintiff
Anthony Marian (13−6219)

represented by Eben P. Colby (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address)

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 117 of 250

ATTORNEY TO BE NOTICED

Peter Simshauser (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Consol Plaintiff
Jacob Mathew (13−6219)

represented by Eben P. Colby (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Peter Simshauser (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Consol Plaintiff
Shaju Olangattu Mathew (13−6219)

represented by Eben P. Colby (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Peter Simshauser (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Consol Plaintiff

represented by

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 118 of 250

Davis Mathai Meledan (13−6219)

Eben P. Colby (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Peter Simshauser (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Consol Plaintiff
Francis Kottackal Ouseph (13−6219)

represented by Eben P. Colby (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Peter Simshauser (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Consol Plaintiff
Purayil Arjunan Padinhare (13−6219)

represented by Eben P. Colby (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 119 of 250

Peter Simshauser (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Consol Plaintiff
Sudheeran Panayamthatta (13−6219)

represented by Eben P. Colby (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Peter Simshauser (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Consol Plaintiff
Telson Joseph Pazhampilly (13−6219)

represented by Eben P. Colby (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Peter Simshauser (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Consol Plaintiff

Sreekumar Janardhanan represented by Eben P. Colby

Pillai

(See above for address)

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 120 of 250

(13−6219)

LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Peter Simshauser (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Consol Plaintiff
Pradeep Chembil Raman (13−6219)

represented by Eben P. Colby (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Peter Simshauser (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Consol Plaintiff
Shawkat Ali Shaikh (13−6219)

represented by Eben P. Colby (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Peter Simshauser

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 121 of 250

(See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Consol Plaintiff
Arunkumar Shaw Narayan Shaw (13−6219)

represented by Eben P. Colby (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Peter Simshauser (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Consol Plaintiff
Subash Chandra Shukla (13−6219)

represented by Eben P. Colby (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Peter Simshauser (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Consol Plaintiff
Ajith Chellayyan Swarnamma (13−6219)

represented by Eben P. Colby (See above for address) LEAD ATTORNEY PRO HAC VICE

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 122 of 250

ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Peter Simshauser (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Consol Plaintiff
Shibu Thankachan (13−6219)

represented by Eben P. Colby (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Peter Simshauser (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Consol Plaintiff
Shajan Varghese (13−6219)

represented by Eben P. Colby (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Peter Simshauser (See above for address) PRO HAC VICE

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 123 of 250

ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Consol Plaintiff
Thomas Varghese Vattakkattu (13−6219)

represented by Eben P. Colby (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Peter Simshauser (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Consol Plaintiff
Jeegan Joseph Cheruthalakal Michael (13−6219)

represented by Eben P. Colby (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Peter Simshauser (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Consol Plaintiff
Gopalakrishnan Unniampathu Vettical Nair (13−6219)

represented by Eben P. Colby (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 124 of 250

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Peter Simshauser (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Consol Plaintiff
Prakash Kuttiyil Chandrasekharan Nair (13−6219)

represented by Eben P. Colby (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Peter Simshauser (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Consol Plaintiff
Jaison Antony Thekkumpuram (13−6219)

represented by Eben P. Colby (See above for address) LEAD ATTORNEY PRO HAC VICE ATTORNEY TO BE NOTICED

Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Peter Simshauser (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 125 of 250

Robert B. McDuff (See above for address) TERMINATED: 12/27/2013

Consol Plaintiff
Pravin Kumar Singh (14−732)

represented by Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Ashley M. Sprague Covington & Burling LLP (DC) One City Center 850 Tenth Street NW Washington, DC 20001 202−662−5604 Email: asprague@cov.com ATTORNEY TO BE NOTICED

Danielle E. Johnson Covington & Burling LLP (DC) 1201 Pennsylvania Ave., NW Washington, DC 20004 202−662−5862 Email: djohnson@cov.com TERMINATED: 04/30/2015 PRO HAC VICE

Jose E. Arvelo Covington & Burling LLP (DC) 1201 Pennsylvania Ave., NW Washington, DC 20004 202−662−5474 Fax: 202−778−5474 Email: jarvelo@cov.com PRO HAC VICE ATTORNEY TO BE NOTICED

Joshua D. Asher Covington & Burling LLP (DC) 1201 Pennsylvania Ave., NW Washington, DC 20004 202−662−5456 Email: jasher@cov.com TERMINATED: 12/22/2015 PRO HAC VICE

Mona Mehta Covington & Burling LLP (DC) 1201 Pennsylvania Ave., NW Washington, DC 20004 202−662−5890 Email: mmehta@cov.com TERMINATED: 06/11/2015 PRO HAC VICE

Mostafa M. Abdelkarim Covington & Burling LLP (DC) 1201 Pennsylvania Ave., NW Washington, DC 20004

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 126 of 250

202−662−5183 Email: mabdelkarim@cov.com PRO HAC VICE ATTORNEY TO BE NOTICED

Steven W. Copley (See above for address) ATTORNEY TO BE NOTICED

Consol Plaintiff
Radhakrishnan Nair Mangalathu Vasukuttan (14−732)

represented by Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Ashley M. Sprague (See above for address) ATTORNEY TO BE NOTICED

Danielle E. Johnson (See above for address) TERMINATED: 04/30/2015 PRO HAC VICE

Jose E. Arvelo (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Joshua D. Asher (See above for address) TERMINATED: 12/22/2015 PRO HAC VICE

Mona Mehta (See above for address) TERMINATED: 06/11/2015 PRO HAC VICE

Mostafa M. Abdelkarim (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Steven W. Copley (See above for address) ATTORNEY TO BE NOTICED

Consol Plaintiff
Ganapathi Rao Akkireddi (14−1818)

represented by Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Meredith B. Stewart Southern Poverty Law Center (New Orleans) 1055 St. Charles Ave. Suite 505 New Orleans, LA 70130 504−486−8982

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 127 of 250
Fax: 504−486−8947 Email: meredith.stewart@splcenter.org LEAD ATTORNEY ATTORNEY TO BE NOTICED
A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED
Daniel Werner Southern Poverty Law Center (Atlanta) Immigrant Justice Project 1989 College Avenue NE Atlanta, GA 30317 404−521−6700 Email: daniel.werner@splcenter.org PRO HAC VICE ATTORNEY TO BE NOTICED
Jane W. Parver Arnold & Porter Kaye Scholer LLP 250 West 55th Street New York, NY 10019 212−836−8510 Email: jane.parver@kayescholer.com ATTORNEY TO BE NOTICED
Michael Blechman Arnold & Porter Kaye Scholer LLP 250 West 55th Street New York, NY 10019 212−836−8353 Email: michael.blechman@kayescholer.com ATTORNEY TO BE NOTICED
Michael S. Bullerman Arnold & Porter and Kaye Scholer LLP (Washington) 601 Massachusetts Ave. NW Washington, DC 20001 212−836−8000 Email: michael.bullerman@kayescholer.com ATTORNEY TO BE NOTICED
Randolph S. Sherman Kaye, Scholer, LLP (New York) 425 Park Ave. New York, NY 10022−3509 212−836−8000 Email: randolph.sherman@kayescholer.com PRO HAC VICE ATTORNEY TO BE NOTICED
Sheila Sabrina Boston Arnold & Porter and Kaye Scholer LLP (New York) 399 Park Ave. New York, NY 10022−4690 212−836−8325 Email: sheila.boston@apks.com PRO HAC VICE ATTORNEY TO BE NOTICED
Thomas J. Szivos Arnold & Porter Kaye Scholer LLP 250 West 55th Street New York, NY 10019

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 128 of 250

212−836−8726 Email: thomas.szivos@kayescholer.com ATTORNEY TO BE NOTICED

Tricia Beckles Kaye, Scholer, LLP (New York) 425 Park Ave. New York, NY 10022−3509 212−836−7363 Email: tricia.beckles@kayescholer.com TERMINATED: 09/08/2015 PRO HAC VICE

Yonina Rosenbaum Arnold & Porter Kaye Scholer LLP 250 West 55th Street New York, NY 10019 212−836−8325 Email: yonina.rosenbaum@kayescholer.com ATTORNEY TO BE NOTICED

Consol Plaintiff
Davis Antony (14−1818)

represented by Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Meredith B. Stewart (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Daniel Werner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Jane W. Parver (See above for address) ATTORNEY TO BE NOTICED

Michael Blechman (See above for address) ATTORNEY TO BE NOTICED

Michael S. Bullerman (See above for address) ATTORNEY TO BE NOTICED

Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Sheila Sabrina Boston (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Thomas J. Szivos

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 129 of 250

(See above for address) ATTORNEY TO BE NOTICED

Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE

Yonina Rosenbaum (See above for address) ATTORNEY TO BE NOTICED

Consol Plaintiff
Saji Chettiyara Baby (14−1818)

represented by Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Meredith B. Stewart (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Daniel Werner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Jane W. Parver (See above for address) ATTORNEY TO BE NOTICED

Michael Blechman (See above for address) ATTORNEY TO BE NOTICED

Michael S. Bullerman (See above for address) ATTORNEY TO BE NOTICED

Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Sheila Sabrina Boston (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Thomas J. Szivos (See above for address) ATTORNEY TO BE NOTICED

Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE

Yonina Rosenbaum

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 130 of 250

(See above for address) ATTORNEY TO BE NOTICED

Consol Plaintiff
Sarma Venkata Satyanarayana Bhiri (14−1818)

represented by Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Meredith B. Stewart (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Daniel Werner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Jane W. Parver (See above for address) ATTORNEY TO BE NOTICED

Michael Blechman (See above for address) ATTORNEY TO BE NOTICED

Michael S. Bullerman (See above for address) ATTORNEY TO BE NOTICED

Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Sheila Sabrina Boston (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Thomas J. Szivos (See above for address) ATTORNEY TO BE NOTICED

Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE

Yonina Rosenbaum (See above for address) ATTORNEY TO BE NOTICED

Consol Plaintiff
Venkatarao Buridi (14−1818)

represented by Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 131 of 250

Meredith B. Stewart (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Daniel Werner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Jane W. Parver (See above for address) ATTORNEY TO BE NOTICED

Michael Blechman (See above for address) ATTORNEY TO BE NOTICED

Michael S. Bullerman (See above for address) ATTORNEY TO BE NOTICED

Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Sheila Sabrina Boston (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Thomas J. Szivos (See above for address) ATTORNEY TO BE NOTICED

Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE

Yonina Rosenbaum (See above for address) ATTORNEY TO BE NOTICED

Consol Plaintiff
Sunny Cherian (14−1818)

represented by Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Meredith B. Stewart (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 132 of 250

Daniel Werner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Jane W. Parver (See above for address) ATTORNEY TO BE NOTICED

Michael Blechman (See above for address) ATTORNEY TO BE NOTICED

Michael S. Bullerman (See above for address) ATTORNEY TO BE NOTICED

Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Sheila Sabrina Boston (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Thomas J. Szivos (See above for address) ATTORNEY TO BE NOTICED

Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE

Yonina Rosenbaum (See above for address) ATTORNEY TO BE NOTICED

Consol Plaintiff
Philip Pindakadavil George (14−1818)

represented by Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Meredith B. Stewart (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Daniel Werner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Jane W. Parver (See above for address) ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 133 of 250

Michael Blechman (See above for address) ATTORNEY TO BE NOTICED

Michael S. Bullerman (See above for address) ATTORNEY TO BE NOTICED

Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Sheila Sabrina Boston (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Thomas J. Szivos (See above for address) ATTORNEY TO BE NOTICED

Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE

Yonina Rosenbaum (See above for address) ATTORNEY TO BE NOTICED

Consol Plaintiff
Zakir Husain Ghulam Husain (14−1818)

represented by Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Meredith B. Stewart (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Daniel Werner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Jane W. Parver (See above for address) ATTORNEY TO BE NOTICED

Michael Blechman (See above for address) ATTORNEY TO BE NOTICED

Michael S. Bullerman (See above for address) ATTORNEY TO BE NOTICED

Randolph S. Sherman

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 134 of 250

(See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Sheila Sabrina Boston (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Thomas J. Szivos (See above for address) ATTORNEY TO BE NOTICED

Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE

Yonina Rosenbaum (See above for address) ATTORNEY TO BE NOTICED

Consol Plaintiff
Mathew Jackson (14−1818)

represented by Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Meredith B. Stewart (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Daniel Werner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Jane W. Parver (See above for address) ATTORNEY TO BE NOTICED

Michael Blechman (See above for address) ATTORNEY TO BE NOTICED

Michael S. Bullerman (See above for address) ATTORNEY TO BE NOTICED

Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Sheila Sabrina Boston (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 135 of 250

Thomas J. Szivos (See above for address) ATTORNEY TO BE NOTICED

Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE

Yonina Rosenbaum (See above for address) ATTORNEY TO BE NOTICED

Consol Plaintiff
Gogy Joseph (14−1818)

represented by Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Meredith B. Stewart (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Daniel Werner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Jane W. Parver (See above for address) ATTORNEY TO BE NOTICED

Michael Blechman (See above for address) ATTORNEY TO BE NOTICED

Michael S. Bullerman (See above for address) ATTORNEY TO BE NOTICED

Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Sheila Sabrina Boston (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Thomas J. Szivos (See above for address) ATTORNEY TO BE NOTICED

Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 136 of 250

Yonina Rosenbaum (See above for address) ATTORNEY TO BE NOTICED

Consol Plaintiff
Joshy Kaiprampattu Joseph (14−1818)

represented by Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Meredith B. Stewart (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Daniel Werner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Jane W. Parver (See above for address) ATTORNEY TO BE NOTICED

Michael Blechman (See above for address) ATTORNEY TO BE NOTICED

Michael S. Bullerman (See above for address) ATTORNEY TO BE NOTICED

Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Sheila Sabrina Boston (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Thomas J. Szivos (See above for address) ATTORNEY TO BE NOTICED

Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE

Yonina Rosenbaum (See above for address) ATTORNEY TO BE NOTICED

Consol Plaintiff
Shanoj Joseph (14−1818)

represented by Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 137 of 250

Consol Plaintiff
Srinu Kalla (14−1818)

Meredith B. Stewart (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED
Daniel Werner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Jane W. Parver (See above for address) ATTORNEY TO BE NOTICED
Michael Blechman (See above for address) ATTORNEY TO BE NOTICED
Michael S. Bullerman (See above for address) ATTORNEY TO BE NOTICED
Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Sheila Sabrina Boston (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Thomas J. Szivos (See above for address) ATTORNEY TO BE NOTICED
Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE
Yonina Rosenbaum (See above for address) ATTORNEY TO BE NOTICED
represented by Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Meredith B. Stewart (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 138 of 250

Consol Plaintiff
Joseph Thomas Kanjiraparambil (14−1818)

Daniel Werner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Jane W. Parver (See above for address) ATTORNEY TO BE NOTICED
Michael Blechman (See above for address) ATTORNEY TO BE NOTICED
Michael S. Bullerman (See above for address) ATTORNEY TO BE NOTICED
Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Sheila Sabrina Boston (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Thomas J. Szivos (See above for address) ATTORNEY TO BE NOTICED
Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE
Yonina Rosenbaum (See above for address) ATTORNEY TO BE NOTICED
represented by Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Meredith B. Stewart (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED
Daniel Werner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Jane W. Parver (See above for address) ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 139 of 250

Consol Plaintiff
Subranarayanan Karuppiah (14−1818)

Michael Blechman (See above for address) ATTORNEY TO BE NOTICED
Michael S. Bullerman (See above for address) ATTORNEY TO BE NOTICED
Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Sheila Sabrina Boston (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Thomas J. Szivos (See above for address) ATTORNEY TO BE NOTICED
Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE
Yonina Rosenbaum (See above for address) ATTORNEY TO BE NOTICED
represented by Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Meredith B. Stewart (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED
Daniel Werner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Jane W. Parver (See above for address) ATTORNEY TO BE NOTICED
Michael Blechman (See above for address) ATTORNEY TO BE NOTICED
Michael S. Bullerman (See above for address) ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 140 of 250

Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Sheila Sabrina Boston (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Thomas J. Szivos (See above for address) ATTORNEY TO BE NOTICED

Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE

Yonina Rosenbaum (See above for address) ATTORNEY TO BE NOTICED

Consol Plaintiff
Maheshwara Rao Molletti (14−1818)

represented by Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Meredith B. Stewart (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Daniel Werner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Jane W. Parver (See above for address) ATTORNEY TO BE NOTICED

Michael Blechman (See above for address) ATTORNEY TO BE NOTICED

Michael S. Bullerman (See above for address) ATTORNEY TO BE NOTICED

Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Sheila Sabrina Boston (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

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Consol Plaintiff
Sivakumar Ramakrishnan Nair (14−1818)

Thomas J. Szivos (See above for address) ATTORNEY TO BE NOTICED
Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE
Yonina Rosenbaum (See above for address) ATTORNEY TO BE NOTICED
represented by Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Meredith B. Stewart (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED
Daniel Werner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Jane W. Parver (See above for address) ATTORNEY TO BE NOTICED
Michael Blechman (See above for address) ATTORNEY TO BE NOTICED
Michael S. Bullerman (See above for address) ATTORNEY TO BE NOTICED
Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Sheila Sabrina Boston (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Thomas J. Szivos (See above for address) ATTORNEY TO BE NOTICED
Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 142 of 250

Yonina Rosenbaum (See above for address) ATTORNEY TO BE NOTICED

Consol Plaintiff
Reghunadhan Palachuvattilpu Narayanannair (14−1818)

represented by Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Meredith B. Stewart (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Daniel Werner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Jane W. Parver (See above for address) ATTORNEY TO BE NOTICED

Michael Blechman (See above for address) ATTORNEY TO BE NOTICED

Michael S. Bullerman (See above for address) ATTORNEY TO BE NOTICED

Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Sheila Sabrina Boston (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Thomas J. Szivos (See above for address) ATTORNEY TO BE NOTICED

Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE

Yonina Rosenbaum (See above for address) ATTORNEY TO BE NOTICED

Consol Plaintiff
Bhaskararao Nimmadala (14−1818)

represented by Meredith S. Grabill (See above for address) LEAD ATTORNEY

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ATTORNEY TO BE NOTICED

Meredith B. Stewart (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Daniel Werner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Jane W. Parver (See above for address) ATTORNEY TO BE NOTICED

Michael Blechman (See above for address) ATTORNEY TO BE NOTICED

Michael S. Bullerman (See above for address) ATTORNEY TO BE NOTICED

Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Sheila Sabrina Boston (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Thomas J. Szivos (See above for address) ATTORNEY TO BE NOTICED

Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE

Yonina Rosenbaum (See above for address) ATTORNEY TO BE NOTICED

Consol Plaintiff
Babu Karippai Ouseph (14−1818)

represented by Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Meredith B. Stewart (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address)

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 144 of 250

ATTORNEY TO BE NOTICED

Daniel Werner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Jane W. Parver (See above for address) ATTORNEY TO BE NOTICED

Michael Blechman (See above for address) ATTORNEY TO BE NOTICED

Michael S. Bullerman (See above for address) ATTORNEY TO BE NOTICED

Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Sheila Sabrina Boston (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Thomas J. Szivos (See above for address) ATTORNEY TO BE NOTICED

Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE

Yonina Rosenbaum (See above for address) ATTORNEY TO BE NOTICED

Consol Plaintiff
Baiju Paul (14−1818)

represented by Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Meredith B. Stewart (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Daniel Werner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Jane W. Parver (See above for address)

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 145 of 250

ATTORNEY TO BE NOTICED

Michael Blechman (See above for address) ATTORNEY TO BE NOTICED

Michael S. Bullerman (See above for address) ATTORNEY TO BE NOTICED

Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Sheila Sabrina Boston (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Thomas J. Szivos (See above for address) ATTORNEY TO BE NOTICED

Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE

Yonina Rosenbaum (See above for address) ATTORNEY TO BE NOTICED

Consol Plaintiff
Rajan Pazhambalakode (14−1818)

represented by Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Meredith B. Stewart (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Daniel Werner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Jane W. Parver (See above for address) ATTORNEY TO BE NOTICED

Michael Blechman (See above for address) ATTORNEY TO BE NOTICED

Michael S. Bullerman (See above for address) ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 146 of 250

Consol Plaintiff
Kantibhai Khemabhai Prajapati (14−1818)

Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Sheila Sabrina Boston (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Thomas J. Szivos (See above for address) ATTORNEY TO BE NOTICED
Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE
Yonina Rosenbaum (See above for address) ATTORNEY TO BE NOTICED
represented by Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Meredith B. Stewart (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED
Daniel Werner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Jane W. Parver (See above for address) ATTORNEY TO BE NOTICED
Michael Blechman (See above for address) ATTORNEY TO BE NOTICED
Michael S. Bullerman (See above for address) ATTORNEY TO BE NOTICED
Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Sheila Sabrina Boston (See above for address) PRO HAC VICE

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 147 of 250

ATTORNEY TO BE NOTICED

Thomas J. Szivos (See above for address) ATTORNEY TO BE NOTICED

Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE

Yonina Rosenbaum (See above for address) ATTORNEY TO BE NOTICED

Consol Plaintiff
Ravi Thammina (14−1818)

represented by Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Meredith B. Stewart (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Daniel Werner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Jane W. Parver (See above for address) ATTORNEY TO BE NOTICED

Michael Blechman (See above for address) ATTORNEY TO BE NOTICED

Michael S. Bullerman (See above for address) ATTORNEY TO BE NOTICED

Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Sheila Sabrina Boston (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Thomas J. Szivos (See above for address) ATTORNEY TO BE NOTICED

Tricia Beckles (See above for address) TERMINATED: 09/08/2015

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 148 of 250

PRO HAC VICE

Yonina Rosenbaum (See above for address) ATTORNEY TO BE NOTICED

Consol Plaintiff
Assari Krishnan Thankappan (14−1818)

represented by Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Meredith B. Stewart (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Daniel Werner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Jane W. Parver (See above for address) ATTORNEY TO BE NOTICED

Michael Blechman (See above for address) ATTORNEY TO BE NOTICED

Michael S. Bullerman (See above for address) ATTORNEY TO BE NOTICED

Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Sheila Sabrina Boston (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Thomas J. Szivos (See above for address) ATTORNEY TO BE NOTICED

Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE

Yonina Rosenbaum (See above for address) ATTORNEY TO BE NOTICED

Consol Plaintiff
George Kutty Puthiya P Thomas

represented by Meredith S. Grabill (See above for address)

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(14−1818)

LEAD ATTORNEY ATTORNEY TO BE NOTICED

Meredith B. Stewart (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Daniel Werner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Jane W. Parver (See above for address) ATTORNEY TO BE NOTICED

Michael Blechman (See above for address) ATTORNEY TO BE NOTICED

Michael S. Bullerman (See above for address) ATTORNEY TO BE NOTICED

Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Sheila Sabrina Boston (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Thomas J. Szivos (See above for address) ATTORNEY TO BE NOTICED

Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE

Yonina Rosenbaum (See above for address) ATTORNEY TO BE NOTICED

Consol Plaintiff
David Raju Tuloori (14−1818)

represented by Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Meredith B. Stewart (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 150 of 250

(See above for address) ATTORNEY TO BE NOTICED

Daniel Werner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Jane W. Parver (See above for address) ATTORNEY TO BE NOTICED

Michael Blechman (See above for address) ATTORNEY TO BE NOTICED

Michael S. Bullerman (See above for address) ATTORNEY TO BE NOTICED

Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Sheila Sabrina Boston (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Thomas J. Szivos (See above for address) ATTORNEY TO BE NOTICED

Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE

Yonina Rosenbaum (See above for address) ATTORNEY TO BE NOTICED

Consol Plaintiff
Satyanarayana Vangapandu (14−1818)

represented by Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Meredith B. Stewart (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Daniel Werner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Jane W. Parver

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 151 of 250

(See above for address) ATTORNEY TO BE NOTICED

Michael Blechman (See above for address) ATTORNEY TO BE NOTICED

Michael S. Bullerman (See above for address) ATTORNEY TO BE NOTICED

Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Sheila Sabrina Boston (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Thomas J. Szivos (See above for address) ATTORNEY TO BE NOTICED

Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE

Yonina Rosenbaum (See above for address) ATTORNEY TO BE NOTICED

Consol Plaintiff
Yacob Thachil Varghese (14−1818)

represented by Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Meredith B. Stewart (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Daniel Werner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Jane W. Parver (See above for address) ATTORNEY TO BE NOTICED

Michael Blechman (See above for address) ATTORNEY TO BE NOTICED

Michael S. Bullerman (See above for address)

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 152 of 250

ATTORNEY TO BE NOTICED

Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Sheila Sabrina Boston (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Thomas J. Szivos (See above for address) ATTORNEY TO BE NOTICED

Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE

Yonina Rosenbaum (See above for address) ATTORNEY TO BE NOTICED

Consol Plaintiff
Antoney Tharayil Xavier (14−1818)

represented by Meredith S. Grabill (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Meredith B. Stewart (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal (See above for address) ATTORNEY TO BE NOTICED

Daniel Werner (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Jane W. Parver (See above for address) ATTORNEY TO BE NOTICED

Michael Blechman (See above for address) ATTORNEY TO BE NOTICED

Michael S. Bullerman (See above for address) ATTORNEY TO BE NOTICED

Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Sheila Sabrina Boston (See above for address)

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 153 of 250
PRO HAC VICE ATTORNEY TO BE NOTICED
Thomas J. Szivos (See above for address) ATTORNEY TO BE NOTICED
Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE
Yonina Rosenbaum (See above for address) ATTORNEY TO BE NOTICED

V.
Defendant
Signal International, LLC

represented by Erin Casey Hangartner Hangartner, Rydberg, Terrell & Hart, LLC One Shell Square 701 Poydras Street Suite 310 New Orleans, LA 70139 (504) 522−5690 Email: ehangartner@hanrylaw.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Alan Dean Weinberger Hangartner, Rydberg, Terrell & Hart, LLC One Shell Square 701 Poydras Street Suite 310 New Orleans, LA 70139 504−522−5690 Fax: 504−581−5983 Email: aweinberger@hanrylaw.com ATTORNEY TO BE NOTICED
Brian C. Roux Hangartner, Rydberg, Terrell & Hart, LLC One Shell Square 701 Poydras Street Suite 310 New Orleans, LA 70139 504−522−5690 Email: broux@hanrylaw.com TERMINATED: 11/30/2016
Dominic Joseph Gianna Aaron & Gianna, PLC 201 St. Charles Avenue Suite 3800 New Orleans, LA 70170 (504) 569−1800 Email: dgianna@aarongianna.com TERMINATED: 03/19/2014
Elham Rabbani Hangartner, Rydberg, Terrell & Hart, LLC One Shell Square 701 Poydras Street

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 154 of 250

Suite 310 New Orleans, LA 70139 504−522−5690 Email: erabbani@hanrylaw.com ATTORNEY TO BE NOTICED

Hal D. Ungar Ogletree, Deakins, Nash, Smoak & Stewart (New Orleans) 701 Poydras St. Suite 3500 New Orleans, LA 70139 504−648−3840 Email: hal.ungar@ogletreedeakins.com TERMINATED: 02/04/2016

James L. Cornblatt Patricia A. Bollman, APLC 3636 S. I−10 Service Road West Metairie, LA 70001 504−218−5887 Email: jcornblatt25@gmail.com PRO HAC VICE ATTORNEY TO BE NOTICED

Lance R. Rydberg Hangartner, Rydberg, Terrell & Hart, LLC One Shell Square 701 Poydras Street Suite 310 New Orleans, LA 70139 (504) 522−5690 Fax: (504) 522−5689 Email: lrydberg@hanrylaw.com ATTORNEY TO BE NOTICED

Mitchell P. Hasenkampf Hangartner, Rydberg, Terrell & Hart, LLC One Shell Square 701 Poydras Street Suite 310 New Orleans, LA 70139 504−522−5690 Email: mhasenkampf@hanrylaw.com ATTORNEY TO BE NOTICED

Patricia Anne F. Bollman The Kullman Firm 1100 Poydras Street Suite 1600 New Orleans, LA 70163 504−596−4123 Email: pab@kullmanlaw.com ATTORNEY TO BE NOTICED

Defendant Signal International, Inc.

represented by Erin Casey Hangartner (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Alan Dean Weinberger (See above for address) ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 155 of 250

Brian C. Roux (See above for address) TERMINATED: 11/30/2016

Dominic Joseph Gianna (See above for address) TERMINATED: 03/19/2014

Elham Rabbani (See above for address) ATTORNEY TO BE NOTICED

Hal D. Ungar (See above for address) TERMINATED: 02/04/2016

James L. Cornblatt (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Lance R. Rydberg (See above for address) ATTORNEY TO BE NOTICED

Mitchell P. Hasenkampf (See above for address) ATTORNEY TO BE NOTICED

Patricia Anne F. Bollman (See above for address) ATTORNEY TO BE NOTICED

Defendant
Malvern C. Burnett TERMINATED: 10/05/2015

represented by Arthur D. Carlisle ARTHUR D. CARLISLE, ATTORNEY 900 Washington Avenue Ocean Springs, MS 39564 228/872−5568 Fax: 228/875−6702 Email: adclaw78@gmail.com TERMINATED: 10/31/2013 LEAD ATTORNEY PRO HAC VICE

Daniel Edwin Buras , Jr. Chehardy,Sherman,Williams,Murray,Recile,Stakelum&Hayes, LLC One Galleria Blvd. Suite 1100 Metairie, LA 70001 504−833−5600 Fax: 888−383−4079 Email: DB@Chehardy.com LEAD ATTORNEY ATTORNEY TO BE NOTICED

Timothy W. Cerniglia Law Office of Timothy W. Cerniglia 1521 St. Charles Ave. New Orleans, LA 70130 504−586−0555 Fax: 504−586−0550 Email: tcerniglia@cerniglialaw.pro

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 156 of 250

LEAD ATTORNEY ATTORNEY TO BE NOTICED

Defendant
Law Offices of Malvern C. Burnett, A.P.C. TERMINATED: 10/05/2015

represented by Arthur D. Carlisle (See above for address) TERMINATED: 10/31/2013 LEAD ATTORNEY PRO HAC VICE

Daniel Edwin Buras , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Timothy W. Cerniglia (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Defendant
Gulf Coast Immigration Law Center, L.L.C. TERMINATED: 10/05/2015

represented by Arthur D. Carlisle (See above for address) TERMINATED: 10/31/2013 LEAD ATTORNEY PRO HAC VICE

Daniel Edwin Buras , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Timothy W. Cerniglia (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Defendant Michael Pol

Defendant Global Resources Inc

Defendant
Sachin Dewan TERMINATED: 12/16/2015

represented by Stephen H. Shapiro Stephen H. Shapiro, Attorney at Law 700 Camp St. New Orleans, LA 70130 504−309−8442 Email: shapesq1@cox.net LEAD ATTORNEY ATTORNEY TO BE NOTICED

Defendant
Dewan Consultants Pvt. Ltd. TERMINATED: 12/16/2015 also known as Medtech Consultants

represented by Stephen H. Shapiro (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

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Defendant
Signal International Texas, G.P.

represented by Erin Casey Hangartner (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Alan Dean Weinberger (See above for address) ATTORNEY TO BE NOTICED

Brian C. Roux (See above for address) TERMINATED: 11/30/2016

Elham Rabbani (See above for address) ATTORNEY TO BE NOTICED

Hal D. Ungar (See above for address) TERMINATED: 02/04/2016

Kevin P. Maney Hangartner, Rydberg, Terrell & Hart, LLC One Shell Square 701 Poydras Street Suite 310 New Orleans, LA 70139 504−434−6824 Email: kmaney@hanrylaw.com ATTORNEY TO BE NOTICED

Lance R. Rydberg (See above for address) ATTORNEY TO BE NOTICED

Lauren Masur Davis Matthiesen, Wickert & Lehrer, SC (New Orleans) 101 W. Robert E. Lee Blvd., Suite 401 New Orleans, LA 70124 262−673−7850 Email: ldavis@mwl−law.com ATTORNEY TO BE NOTICED

Mitchell P. Hasenkampf (See above for address) ATTORNEY TO BE NOTICED

Patricia Anne F. Bollman (See above for address) ATTORNEY TO BE NOTICED

Robert Louis Keller Hangartner, Rydberg, Terrell & Hart, LLC One Shell Square 701 Poydras Street Suite 310 New Orleans, LA 70139 504−522−5690 Email: rkeller@hanrylaw.com ATTORNEY TO BE NOTICED

Defendant

represented by

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Signal International Texas, L.P.

Erin Casey Hangartner (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Alan Dean Weinberger (See above for address) ATTORNEY TO BE NOTICED

Brian C. Roux (See above for address) TERMINATED: 11/30/2016

Elham Rabbani (See above for address) ATTORNEY TO BE NOTICED

Hal D. Ungar (See above for address) TERMINATED: 02/04/2016

Kevin P. Maney (See above for address) ATTORNEY TO BE NOTICED

Lance R. Rydberg (See above for address) ATTORNEY TO BE NOTICED

Lauren Masur Davis (See above for address) ATTORNEY TO BE NOTICED

Mitchell P. Hasenkampf (See above for address) ATTORNEY TO BE NOTICED

Patricia Anne F. Bollman (See above for address) ATTORNEY TO BE NOTICED

Robert Louis Keller (See above for address) ATTORNEY TO BE NOTICED

V. Consol Defendant Indo−Amerisoft LLC (13−6220) Consol Defendant Kurella Rao (13−6220)
Consol Defendant J&M Associates, Inc. of Mississippi

represented by Kurella Rao #6 Isla Road, Unity Zone Dangriga Belize 501−638−3820 PRO SE

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(13−6219, 14−1818)

Consol Defendant
Billy R Wilks (13−6219, 14−1818)

represented by Billy R Wilks 9136 Heather Lane Moss Point, MS 39562 (228) 475−7340 PRO SE

Consol Defendant
Indo−Amerisoft LLC (13−6221)

Consol Defendant
Signal International, LLC (13−6219, 13−6221, 14−732, 14−1818)

represented by Erin Casey Hangartner (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Alan Dean Weinberger (See above for address) ATTORNEY TO BE NOTICED

Brian C. Roux (See above for address) TERMINATED: 11/30/2016

Dominic Joseph Gianna (See above for address) TERMINATED: 03/19/2014

Elham Rabbani (See above for address) ATTORNEY TO BE NOTICED

Hal D. Ungar (See above for address) TERMINATED: 02/04/2016

James L. Cornblatt (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Lance R. Rydberg (See above for address) ATTORNEY TO BE NOTICED

Mitchell P. Hasenkampf (See above for address) ATTORNEY TO BE NOTICED

Patricia Anne F. Bollman (See above for address) ATTORNEY TO BE NOTICED

Consol Defendant
Signal International, Inc. (13−6219, 13−6221, 14−732, 14−1818)

represented by Erin Casey Hangartner (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 160 of 250

Alan Dean Weinberger (See above for address) ATTORNEY TO BE NOTICED

Brian C. Roux (See above for address) TERMINATED: 11/30/2016

Dominic Joseph Gianna (See above for address) TERMINATED: 03/19/2014

Elham Rabbani (See above for address) ATTORNEY TO BE NOTICED

Hal D. Ungar (See above for address) TERMINATED: 02/04/2016

James L. Cornblatt (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Lance R. Rydberg (See above for address) ATTORNEY TO BE NOTICED

Mitchell P. Hasenkampf (See above for address) ATTORNEY TO BE NOTICED

Patricia Anne F. Bollman (See above for address) ATTORNEY TO BE NOTICED

Consol Defendant
Malvern C. Burnett (13−6219 − Dismissed 10/5/2015, 13−6220, 13−6221, 14−732, 14−1818) TERMINATED: 04/07/2017

represented by Arthur D. Carlisle (See above for address) TERMINATED: 10/31/2013 LEAD ATTORNEY PRO HAC VICE
Daniel Edwin Buras , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Timothy W. Cerniglia (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Consol Defendant
Law Offices of Malvern C. Burnett, A.P.C. (13−6219 − Dismissed 10/5/2015, 13−6220, 13−6221, 14−732, 14−1818) TERMINATED: 04/07/2017

represented by Arthur D. Carlisle (See above for address) TERMINATED: 10/31/2013 LEAD ATTORNEY PRO HAC VICE
Daniel Edwin Buras , Jr. (See above for address) LEAD ATTORNEY

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 161 of 250

ATTORNEY TO BE NOTICED

Timothy W. Cerniglia (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Consol Defendant
Gulf Coast Immigration Law Center, L.L.C. (13−6219 − Dismissed 10/5/2015, 13−6220, 13−6221, 14−732, 14−1818) TERMINATED: 04/07/2017

represented by Arthur D. Carlisle (See above for address) TERMINATED: 10/31/2013 LEAD ATTORNEY PRO HAC VICE
Daniel Edwin Buras , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Timothy W. Cerniglia (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Consol Defendant
J&M Marine & Industrial, LLC (13−6219, 14−1818)

Consol Defendant
Global Resources, Inc. (13−6219, 13−6220, 13−6221, 14−732, 14−1818)

Consol Defendant
Sachin Dewan (13−6219, 13−6220, 13−6221, 14−732, 14−1818) TERMINATED: 04/07/2017

represented by Stephen H. Shapiro (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Consol Defendant
Dewan Consultants Pvt. Ltd. (13−6219, 13−6220, 13−6221, 14−732, 14−1818) TERMINATED: 04/07/2017 doing business as Medtech Consultants

represented by Stephen H. Shapiro (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Consol Defendant
Signal International LLC (13−6220)

represented by Erin Casey Hangartner (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Alan Dean Weinberger

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 162 of 250

(See above for address) ATTORNEY TO BE NOTICED

Brian C. Roux (See above for address) TERMINATED: 11/30/2016

Dominic Joseph Gianna (See above for address) TERMINATED: 03/19/2014

Elham Rabbani (See above for address) ATTORNEY TO BE NOTICED

Hal D. Ungar (See above for address) TERMINATED: 02/04/2016

James L. Cornblatt (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Lance R. Rydberg (See above for address) ATTORNEY TO BE NOTICED

Lauren Masur Davis (See above for address) ATTORNEY TO BE NOTICED

Mitchell P. Hasenkampf (See above for address) ATTORNEY TO BE NOTICED

Patricia Anne F. Bollman (See above for address) ATTORNEY TO BE NOTICED

Consol Defendant
Kurella Sada Siva Rao (13−6221)

Consol Defendant
Michael Pol (13−6221) TERMINATED: 11/07/2013

Consol Defendant
Signal International Texas GP, LLC (14−1818)

Consol Defendant
Signal International Texas, L.P. (14−1818)

represented by Erin Casey Hangartner Hangartner, Rydberg, Terrell & Hart, LLC
One Shell Square 701 Poydras Street Suite 310

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 163 of 250

New Orleans, LA 70139 (504) 522−5690 Fax: Email: ehangartner@hanrylaw.com LEAD ATTORNEY ATTORNEY TO BE NOTICED

Alan Dean Weinberger (See above for address) ATTORNEY TO BE NOTICED

Brian C. Roux (See above for address) TERMINATED: 11/30/2016

Elham Rabbani (See above for address) ATTORNEY TO BE NOTICED

Hal D. Ungar (See above for address) TERMINATED: 02/04/2016

Kevin P. Maney (See above for address) ATTORNEY TO BE NOTICED

Lance R. Rydberg (See above for address) ATTORNEY TO BE NOTICED

Lauren Masur Davis (See above for address) ATTORNEY TO BE NOTICED

Mitchell P. Hasenkampf (See above for address) ATTORNEY TO BE NOTICED

Patricia Anne F. Bollman (See above for address) ATTORNEY TO BE NOTICED

Robert Louis Keller (See above for address) ATTORNEY TO BE NOTICED

Cross Claimant World Marine, LLC

represented by Erin Casey Hangartner (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Alan Dean Weinberger (See above for address) ATTORNEY TO BE NOTICED

Brian C. Roux (See above for address) TERMINATED: 11/30/2016

Elham Rabbani (See above for address) ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 164 of 250

Cross Claimant Signal International, LLC TERMINATED: 01/21/2016
Cross Claimant

Lance R. Rydberg (See above for address) ATTORNEY TO BE NOTICED
Lauren Masur Davis (See above for address) ATTORNEY TO BE NOTICED
Mitchell P. Hasenkampf (See above for address) ATTORNEY TO BE NOTICED
Patricia Anne F. Bollman (See above for address) ATTORNEY TO BE NOTICED
Robert Louis Keller (See above for address) ATTORNEY TO BE NOTICED
represented by Erin Casey Hangartner (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Alan Dean Weinberger (See above for address) ATTORNEY TO BE NOTICED
Brian C. Roux (See above for address) TERMINATED: 11/30/2016
Dominic Joseph Gianna (See above for address) TERMINATED: 03/19/2014
Elham Rabbani (See above for address) ATTORNEY TO BE NOTICED
Hal D. Ungar (See above for address) TERMINATED: 02/04/2016
James L. Cornblatt (See above for address) ATTORNEY TO BE NOTICED
Lance R. Rydberg (See above for address) ATTORNEY TO BE NOTICED
Mitchell P. Hasenkampf (See above for address) ATTORNEY TO BE NOTICED
Patricia Anne F. Bollman (See above for address) ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 165 of 250

Signal International, Inc.

represented by Erin Casey Hangartner (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Alan Dean Weinberger (See above for address) ATTORNEY TO BE NOTICED

Brian C. Roux (See above for address) TERMINATED: 11/30/2016

Dominic Joseph Gianna (See above for address) TERMINATED: 03/19/2014

Elham Rabbani (See above for address) ATTORNEY TO BE NOTICED

Hal D. Ungar (See above for address) TERMINATED: 02/04/2016

James L. Cornblatt (See above for address) ATTORNEY TO BE NOTICED

Lance R. Rydberg (See above for address) ATTORNEY TO BE NOTICED

Mitchell P. Hasenkampf (See above for address) ATTORNEY TO BE NOTICED

Patricia Anne F. Bollman (See above for address) ATTORNEY TO BE NOTICED

Cross Claimant
Signal International Texas, G.P.

represented by Erin Casey Hangartner (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Alan Dean Weinberger (See above for address) ATTORNEY TO BE NOTICED

Brian C. Roux (See above for address) TERMINATED: 11/30/2016

Elham Rabbani (See above for address) ATTORNEY TO BE NOTICED

Hal D. Ungar (See above for address) TERMINATED: 02/04/2016

Kevin P. Maney

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 166 of 250

(See above for address) ATTORNEY TO BE NOTICED

Lance R. Rydberg (See above for address) ATTORNEY TO BE NOTICED

Lauren Masur Davis (See above for address) ATTORNEY TO BE NOTICED

Mitchell P. Hasenkampf (See above for address) ATTORNEY TO BE NOTICED

Patricia Anne F. Bollman (See above for address) ATTORNEY TO BE NOTICED

Robert Louis Keller (See above for address) ATTORNEY TO BE NOTICED

Cross Claimant
Signal International Texas, L.P. TERMINATED: 01/21/2016

represented by Erin Casey Hangartner (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Alan Dean Weinberger (See above for address) ATTORNEY TO BE NOTICED

Brian C. Roux (See above for address) TERMINATED: 11/30/2016

Elham Rabbani (See above for address) ATTORNEY TO BE NOTICED

Hal D. Ungar (See above for address) TERMINATED: 02/04/2016

Kevin P. Maney (See above for address) ATTORNEY TO BE NOTICED

Lance R. Rydberg (See above for address) ATTORNEY TO BE NOTICED

Lauren Masur Davis (See above for address) ATTORNEY TO BE NOTICED

Mitchell P. Hasenkampf (See above for address) ATTORNEY TO BE NOTICED

Patricia Anne F. Bollman (See above for address) ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 167 of 250

Robert Louis Keller (See above for address) ATTORNEY TO BE NOTICED

V. Cross Defendant Malvern C. Burnett
Cross Defendant Sachin Dewan
Cross Defendant Dewan Consultants Pvt. Ltd.
Cross Defendant Global Resources Inc Cross Defendant Indo−Amerisoft LLC (13−6220) Cross Defendant J&M Associates, Inc. of Mississippi (13−6219) Cross Defendant J&M Marine & Industrial, LLC (13−6219) Cross Defendant Law Offices of Malvern C. Burnett, A.P.C.

represented by Arthur D. Carlisle (See above for address) TERMINATED: 10/31/2013 LEAD ATTORNEY Daniel Edwin Buras , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED Timothy W. Cerniglia (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Stephen H. Shapiro (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Stephen H. Shapiro (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Arthur D. Carlisle (See above for address) TERMINATED: 10/31/2013 LEAD ATTORNEY Daniel Edwin Buras , Jr.

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 168 of 250

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Timothy W. Cerniglia (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Cross Defendant Michael Pol

Cross Defendant
Kurella Rao (13−6220)

Cross Defendant
Billy R Wilks (13−6219)

Cross Claimant
Gulf Coast Immigration Law Center, L.L.C. (13−6219, 13−6220, 13−6221, 14−732, 14−1818)

represented by Arthur D. Carlisle (See above for address) TERMINATED: 10/31/2013 LEAD ATTORNEY
Daniel Edwin Buras , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Timothy W. Cerniglia (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

V.
Cross Defendant
Signal International LLC (13−6220)

represented by Erin Casey Hangartner (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Alan Dean Weinberger (See above for address) ATTORNEY TO BE NOTICED
Brian C. Roux (See above for address) TERMINATED: 11/30/2016
Dominic Joseph Gianna (See above for address) TERMINATED: 03/19/2014
Elham Rabbani (See above for address) ATTORNEY TO BE NOTICED
Hal D. Ungar

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 169 of 250

(See above for address) TERMINATED: 02/04/2016

James L. Cornblatt (See above for address) ATTORNEY TO BE NOTICED

Lance R. Rydberg (See above for address) ATTORNEY TO BE NOTICED

Lauren Masur Davis (See above for address) ATTORNEY TO BE NOTICED

Mitchell P. Hasenkampf (See above for address) ATTORNEY TO BE NOTICED

Patricia Anne F. Bollman (See above for address) ATTORNEY TO BE NOTICED

Cross Defendant
Signal International, Inc. (13−6219, 13−6221, 14−732, 14−1818)

represented by Erin Casey Hangartner (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Alan Dean Weinberger (See above for address) ATTORNEY TO BE NOTICED

Brian C. Roux (See above for address) TERMINATED: 11/30/2016

Dominic Joseph Gianna (See above for address) TERMINATED: 03/19/2014

Elham Rabbani (See above for address) ATTORNEY TO BE NOTICED

Hal D. Ungar (See above for address) TERMINATED: 02/04/2016

James L. Cornblatt (See above for address) ATTORNEY TO BE NOTICED

Lance R. Rydberg (See above for address) ATTORNEY TO BE NOTICED

Mitchell P. Hasenkampf (See above for address) ATTORNEY TO BE NOTICED

Patricia Anne F. Bollman (See above for address) ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 170 of 250

Cross Defendant Signal International, LLC (13−6219, 13−6221, 14−732, 14−1818)
Cross Defendant Gulf Coast Immigration Law Center, L.L.C. Cross Claimant Signal International Texas, L.P. TERMINATED: 01/21/2016

represented by Erin Casey Hangartner (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Alan Dean Weinberger (See above for address) ATTORNEY TO BE NOTICED
Brian C. Roux (See above for address) TERMINATED: 11/30/2016
Dominic Joseph Gianna (See above for address) TERMINATED: 03/19/2014
Elham Rabbani (See above for address) ATTORNEY TO BE NOTICED
Hal D. Ungar (See above for address) TERMINATED: 02/04/2016
James L. Cornblatt (See above for address) ATTORNEY TO BE NOTICED
Lance R. Rydberg (See above for address) ATTORNEY TO BE NOTICED
Mitchell P. Hasenkampf (See above for address) ATTORNEY TO BE NOTICED
Patricia Anne F. Bollman (See above for address) ATTORNEY TO BE NOTICED
represented by Timothy W. Cerniglia (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Erin Casey Hangartner (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Alan Dean Weinberger (See above for address) ATTORNEY TO BE NOTICED
Brian C. Roux (See above for address) TERMINATED: 11/30/2016

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 171 of 250

Elham Rabbani (See above for address) ATTORNEY TO BE NOTICED

Hal D. Ungar (See above for address) TERMINATED: 02/04/2016

Kevin P. Maney (See above for address) ATTORNEY TO BE NOTICED

Lance R. Rydberg (See above for address) ATTORNEY TO BE NOTICED

Lauren Masur Davis (See above for address) ATTORNEY TO BE NOTICED

Mitchell P. Hasenkampf (See above for address) ATTORNEY TO BE NOTICED

Patricia Anne F. Bollman (See above for address) ATTORNEY TO BE NOTICED

Robert Louis Keller (See above for address) ATTORNEY TO BE NOTICED

Cross Claimant
Malvern C. Burnett (13−6219, 13−6220, 13−6221, 14−732, 14−1818)

represented by Arthur D. Carlisle (See above for address) TERMINATED: 10/31/2013 LEAD ATTORNEY

Daniel Edwin Buras , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Timothy W. Cerniglia (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Cross Claimant
Law Offices of Malvern C. Burnett, A.P.C.

represented by Arthur D. Carlisle (See above for address) TERMINATED: 10/31/2013 LEAD ATTORNEY

Daniel Edwin Buras , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Timothy W. Cerniglia (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 172 of 250

Cross Claimant Law Offices of Malvern C. Burnett, A.P.C.
Cross Claimant Sachin Dewan
Cross Claimant Dewan Consultants Pvt. Ltd.

represented by Arthur D. Carlisle (See above for address) TERMINATED: 10/31/2013 LEAD ATTORNEY
Daniel Edwin Buras , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Timothy W. Cerniglia (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Stephen H. Shapiro (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Stephen H. Shapiro (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

V.
Cross Defendant
Signal International, Inc. (13−6219, 13−6221, 14−732, 14−1818)

represented by Erin Casey Hangartner (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Alan Dean Weinberger (See above for address) ATTORNEY TO BE NOTICED

Brian C. Roux (See above for address) TERMINATED: 11/30/2016

Dominic Joseph Gianna (See above for address) TERMINATED: 03/19/2014

Elham Rabbani (See above for address) ATTORNEY TO BE NOTICED

Hal D. Ungar (See above for address) TERMINATED: 02/04/2016

James L. Cornblatt (See above for address) ATTORNEY TO BE NOTICED

Lance R. Rydberg

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 173 of 250

(See above for address) ATTORNEY TO BE NOTICED

Mitchell P. Hasenkampf (See above for address) ATTORNEY TO BE NOTICED

Patricia Anne F. Bollman (See above for address) ATTORNEY TO BE NOTICED

Cross Defendant
Signal International, LLC (13−6219, 13−6221, 14−732, 14−1818)

represented by Erin Casey Hangartner (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Alan Dean Weinberger (See above for address) ATTORNEY TO BE NOTICED

Brian C. Roux (See above for address) TERMINATED: 11/30/2016

Dominic Joseph Gianna (See above for address) TERMINATED: 03/19/2014

Elham Rabbani (See above for address) ATTORNEY TO BE NOTICED

Hal D. Ungar (See above for address) TERMINATED: 02/04/2016

James L. Cornblatt (See above for address) ATTORNEY TO BE NOTICED

Lance R. Rydberg (See above for address) ATTORNEY TO BE NOTICED

Mitchell P. Hasenkampf (See above for address) ATTORNEY TO BE NOTICED

Patricia Anne F. Bollman (See above for address) ATTORNEY TO BE NOTICED

Date Filed 05/21/2013

# Docket Text
1 COMPLAINT with Jury Demand against Malvern C. Burnett, Sachin Dewan, Dewan Consultants Pvt. Ltd., Global Resources, Inc., Gulf Coast Immigration Law Center, LLC, Law Offices of Malvern C. Burnett, A.P.C., Michael Pol, Signal International, Inc., Signal International, LLC ( Filing fee $ 400, receipt number 14643004577), filed by Nandhakumar Nagaraj, Shahi Vijayan, Sunilkumar Marottikkal Kuttan, Rajankunju Geevarghese, Biju John, Lakshmanan Ponnayan Achari, Shanmugam Subramanian, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Ninan John Tharakan, Benny Kattukariyil Varkey, George Pulikkeparambil Varghese, Mookaparambil Itty

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 174 of 250

05/21/2013 06/13/2013
06/13/2013 06/14/2013 06/17/2013 06/17/2013 06/18/2013 06/19/2013 06/21/2013

Raveendranathan, Johny Mathew, Shaji Veluthalakuzhiy Nanoo, Shaiju Vadakkal George, Ranjit Singh, Mouleswararao Guntamukkala, Parshottam Ramchandra Mangani, John Yohannan, Jacob Mazhukkattu Mathew, Radhakrishna Pillai Sivarama Pillai, Kodakeril Baby Biji, Jomon George, Balwinder Singh, Aby Molathu Poulose, Joy Jacob, Sreenivasarao Raparthy, Mangalan Chandrasekharan Pillai, Appunni Arul Prakash, Shibu Joseph, Justin Poulose, Xavier Disoliyan. (Attachments: # 1 Civil Cover Sheet)(avm) [Transferred from mssd on 10/23/2013.] (Entered: 05/21/2013)
2 Summons Issued as to Malvern C. Burnett, Sachin Dewan, Dewan Consultants Pvt. Ltd., Global Resources, Inc., Gulf Coast Immigration Law Center, LLC, Law Offices of Malvern C. Burnett, A.P.C., Michael Pol, Signal International, Inc., Signal International, LLC. (avm) [Transferred from mssd on 10/23/2013.] (Entered: 05/21/2013)
3 MOTION for Daniel D. Adams to Appear Pro Hac Vice by Lakshmanan Ponnayan Achari, Kodakeril Baby Biji, Xavier Disoliyan, Rajankunju Geevarghese, Jomon George, Shaiju Vadakkal George, Mouleswararao Guntamukkala, Joy Jacob, Biju John, Shibu Joseph, Sunilkumar Marottikkal Kuttan, Parshottam Ramchandra Mangani, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Jacob Mazhukkattu Mathew, Johny Mathew, Nandhakumar Nagaraj, Shaji Veluthalakuzhiy Nanoo, Mangalan Chandrasekharan Pillai, Radhakrishna Pillai Sivarama Pillai, Aby Molathu Poulose, Justin Poulose, Appunni Arul Prakash, Sreenivasarao Raparthy, Mookaparambil Itty Raveendranathan, Balwinder Singh, Ranjit Singh, Shanmugam Subramanian, Ninan John Tharakan, George Pulikkeparambil Varghese, Benny Kattukariyil Varkey, Shahi Vijayan, John Yohannan (McDuff, Robert) [Transferred from mssd on 10/23/2013.] (Entered: 06/13/2013)
Pro Hac Vice fee paid for Daniel D. Adams receipt number 0538−2439133 $ 100 (McDuff, Robert) [Transferred from mssd on 10/23/2013.] (Entered: 06/13/2013)
DOCKET ANNOTATION as to # 3. 1.) The Motion for Pro Hac and exhibits are filed as one main document. Exhibits should be scanned separately and docketed as properly identified attachments to the main document within the same docket entry. Attorney is directed to follow this procedure in future filings. L.U.Civ.R. 7.(b)(2). 2. ) The certificate of service is undated. Attorney's office is not required to re−file. (JCH) [Transferred from mssd on 10/23/2013.] (Entered: 06/14/2013)
TEXT ORDER ONLY The Court finds that the motion 3 of David S.Adams to be admitted pro hac vice should be granted in association with local counsel upon payment of the appropriate fee and registration for electronic filing as required by the Uniform Local Rules of this Court. No further written order shall be issued by this Court. Signed by Magistrate Judge John M. Roper on June 17,2013 (Nicaud, Jenny) [Transferred from mssd on 10/23/2013.] (Entered: 06/17/2013)
4 Ex Parte MOTION for Extension of Time to File Answer re 1 Complaint, by Signal International, LLC (Attachments: # 1 Order)(Ungar, Hal) [Transferred from mssd on 10/23/2013.] (Entered: 06/17/2013)
DOCKET ANNOTATION as to # 4. Proposed orders are not to be electronically filed as a separate pleading or as an attachment to a pleading, but instead are to be provided to chambers by e−mail (Court's Administrative Procedures for Electronic Case Filing Sec.5.B.). (JCH) [Transferred from mssd on 10/23/2013.] (Entered: 06/18/2013)
TEXT ORDER ONLY The Court finds that Defendant, Signal International L.L.C. must answer or otherwise plead on or prior to July 11,2013. Thus, the Court finds that Defendant, Signal International,LLC 's 4 Motion for Extension of Time to Answer is granted. No further written order shall be issued by this Court. Signed by Magistrate Judge John M. Roper on June 19,2013 (Nicaud, Jenny) [Transferred from mssd on 10/23/2013.] (Entered: 06/19/2013)
5 ** DISREGARD − INCORRECT ATTORNEY ** MOTION for Benton J. Campbell to Appear Pro Hac Vice by Lakshmanan Ponnayan Achari, Kodakeril Baby Biji, Xavier Disoliyan, Rajankunju Geevarghese, Jomon George, Shaiju Vadakkal George, Mouleswararao Guntamukkala, Joy Jacob, Biju John, Shibu Joseph, Sunilkumar Marottikkal Kuttan, Parshottam Ramchandra Mangani, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Jacob Mazhukkattu Mathew, Johny Mathew, Nandhakumar Nagaraj, Shaji Veluthalakuzhiy Nanoo, Mangalan Chandrasekharan

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06/21/2013 06/21/2013
06/21/2013 06/21/2013
06/21/2013 06/21/2013
06/21/2013

Pillai, Radhakrishna Pillai Sivarama Pillai, Aby Molathu Poulose, Justin Poulose, Appunni Arul Prakash, Sreenivasarao Raparthy, Mookaparambil Itty Raveendranathan, Balwinder Singh, Ranjit Singh, Shanmugam Subramanian, Ninan John Tharakan, George Pulikkeparambil Varghese, Benny Kattukariyil Varkey, Shahi Vijayan, John Yohannan (Attachments: # 1 Exhibit Ex 1− Certificate of Good Standing−State, # 2 Exhibit Ex 2−Certificate of Good Standing− Federal District Court)(McDuff, Robert) Modified on 6/21/2013 (avm). [Transferred from mssd on 10/23/2013.] (Entered: 06/21/2013)
DOCKET ANNOTATION as to #5: docket entry incorrect for document attached; attorney is to re−file document. Court staff has termed the motion. (avm) [Transferred from mssd on 10/23/2013.] (Entered: 06/21/2013)
6 MOTION for H. Gregory Baker to Appear Pro Hac Vice by Lakshmanan Ponnayan Achari, Kodakeril Baby Biji, Xavier Disoliyan, Rajankunju Geevarghese, Jomon George, Shaiju Vadakkal George, Mouleswararao Guntamukkala, Joy Jacob, Biju John, Shibu Joseph, Sunilkumar Marottikkal Kuttan, Parshottam Ramchandra Mangani, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Jacob Mazhukkattu Mathew, Johny Mathew, Nandhakumar Nagaraj, Shaji Veluthalakuzhiy Nanoo, Mangalan Chandrasekharan Pillai, Radhakrishna Pillai Sivarama Pillai, Aby Molathu Poulose, Justin Poulose, Appunni Arul Prakash, Sreenivasarao Raparthy, Mookaparambil Itty Raveendranathan, Balwinder Singh, Ranjit Singh, Shanmugam Subramanian, Ninan John Tharakan, George Pulikkeparambil Varghese, Benny Kattukariyil Varkey, Shahi Vijayan, John Yohannan (Attachments: # 1 Exhibit Ex−1 Certificate of Good Standing−State, # 2 Exhibit Certificate of Good Standing− Federal District Court)(McDuff, Robert) [Transferred from mssd on 10/23/2013.] (Entered: 06/21/2013)
Pro Hac Vice fee paid for H. Gregory Baker receipt number 0538−2444686 $ 100 (McDuff, Robert) [Transferred from mssd on 10/23/2013.] (Entered: 06/21/2013)
7 MOTION for Benton J. Campbell to Appear Pro Hac Vice by Lakshmanan Ponnayan Achari, Kodakeril Baby Biji, Xavier Disoliyan, Rajankunju Geevarghese, Jomon George, Shaiju Vadakkal George, Mouleswararao Guntamukkala, Joy Jacob, Biju John, Shibu Joseph, Sunilkumar Marottikkal Kuttan, Parshottam Ramchandra Mangani, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Jacob Mazhukkattu Mathew, Johny Mathew, Nandhakumar Nagaraj, Shaji Veluthalakuzhiy Nanoo, Mangalan Chandrasekharan Pillai, Radhakrishna Pillai Sivarama Pillai, Aby Molathu Poulose, Justin Poulose, Appunni Arul Prakash, Sreenivasarao Raparthy, Mookaparambil Itty Raveendranathan, Balwinder Singh, Ranjit Singh, Shanmugam Subramanian, Ninan John Tharakan, George Pulikkeparambil Varghese, Benny Kattukariyil Varkey, Shahi Vijayan, John Yohannan (Attachments: # 1 Exhibit Ex−1 Certificate of Good Standing− State, # 2 Exhibit Ex−2 Certificate of Good Standing− Federal District Court)(McDuff, Robert) [Transferred from mssd on 10/23/2013.] (Entered: 06/21/2013)
Pro Hac Vice fee paid for Benton J. Campbell receipt number 0538−2444705 $ 100 (McDuff, Robert) [Transferred from mssd on 10/23/2013.] (Entered: 06/21/2013)
8 MOTION for Jennifer Greenburg to Appear Pro Hac Vice by Lakshmanan Ponnayan Achari, Kodakeril Baby Biji, Xavier Disoliyan, Rajankunju Geevarghese, Jomon George, Shaiju Vadakkal George, Mouleswararao Guntamukkala, Joy Jacob, Biju John, Shibu Joseph, Sunilkumar Marottikkal Kuttan, Parshottam Ramchandra Mangani, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Jacob Mazhukkattu Mathew, Johny Mathew, Nandhakumar Nagaraj, Shaji Veluthalakuzhiy Nanoo, Mangalan Chandrasekharan Pillai, Radhakrishna Pillai Sivarama Pillai, Aby Molathu Poulose, Justin Poulose, Appunni Arul Prakash, Sreenivasarao Raparthy, Mookaparambil Itty Raveendranathan, Balwinder Singh, Ranjit Singh, Shanmugam Subramanian, Ninan John Tharakan, George Pulikkeparambil Varghese, Benny Kattukariyil Varkey, Shahi Vijayan, John Yohannan (Attachments: # 1 Exhibit Ex−1 Certificate of Good Standing− State, # 2 Exhibit Ex−2 Certificate of Good Standing− Federal District Court)(McDuff, Robert) [Transferred from mssd on 10/23/2013.] (Entered: 06/21/2013)
Pro Hac Vice fee paid for Jennifer Greenburg receipt number 0538−2444713 $ 100 (McDuff, Robert) [Transferred from mssd on 10/23/2013.] (Entered: 06/21/2013)

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06/21/2013
06/21/2013 06/21/2013
06/21/2013 06/27/2013 07/11/2013 07/11/2013 07/12/2013
07/12/2013

9 MOTION for Christopher Harris to Appear Pro Hac Vice by Lakshmanan Ponnayan Achari, Kodakeril Baby Biji, Xavier Disoliyan, Rajankunju Geevarghese, Jomon George, Shaiju Vadakkal George, Mouleswararao Guntamukkala, Joy Jacob, Biju John, Shibu Joseph, Sunilkumar Marottikkal Kuttan, Parshottam Ramchandra Mangani, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Jacob Mazhukkattu Mathew, Johny Mathew, Nandhakumar Nagaraj, Shaji Veluthalakuzhiy Nanoo, Mangalan Chandrasekharan Pillai, Radhakrishna Pillai Sivarama Pillai, Aby Molathu Poulose, Justin Poulose, Appunni Arul Prakash, Sreenivasarao Raparthy, Mookaparambil Itty Raveendranathan, Balwinder Singh, Ranjit Singh, Shanmugam Subramanian, Ninan John Tharakan, George Pulikkeparambil Varghese, Benny Kattukariyil Varkey, Shahi Vijayan, John Yohannan (Attachments: # 1 Exhibit Ex−1 Certificate of Good Standing−State, # 2 Exhibit Ex−2 Certificate of Good Standing− Federal District Court)(McDuff, Robert) [Transferred from mssd on 10/23/2013.] (Entered: 06/21/2013)
Pro Hac Vice fee paid for Christoper Harris receipt number 0538−2444724 $ 100 (McDuff, Robert) [Transferred from mssd on 10/23/2013.] (Entered: 06/21/2013)
10 MOTION for Miles N. Ruthberg to Appear Pro Hac Vice by Lakshmanan Ponnayan Achari, Kodakeril Baby Biji, Xavier Disoliyan, Rajankunju Geevarghese, Jomon George, Shaiju Vadakkal George, Mouleswararao Guntamukkala, Joy Jacob, Biju John, Shibu Joseph, Sunilkumar Marottikkal Kuttan, Parshottam Ramchandra Mangani, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Jacob Mazhukkattu Mathew, Johny Mathew, Nandhakumar Nagaraj, Shaji Veluthalakuzhiy Nanoo, Mangalan Chandrasekharan Pillai, Radhakrishna Pillai Sivarama Pillai, Aby Molathu Poulose, Justin Poulose, Appunni Arul Prakash, Sreenivasarao Raparthy, Mookaparambil Itty Raveendranathan, Balwinder Singh, Ranjit Singh, Shanmugam Subramanian, Ninan John Tharakan, George Pulikkeparambil Varghese, Benny Kattukariyil Varkey, Shahi Vijayan, John Yohannan (Attachments: # 1 Exhibit Ex−1 Certificate of Good Standing− State, # 2 Exhibit Ex−2 Certificate of Good Standing− Federal District Court)(McDuff, Robert) [Transferred from mssd on 10/23/2013.] (Entered: 06/21/2013)
Pro Hac Vice fee paid for Miles N. Ruthberg receipt number 0538−2444744 $ 100 (McDuff, Robert) [Transferred from mssd on 10/23/2013.] (Entered: 06/21/2013)
TEXT ORDER ONLY The Court finds that the motions of H Gregory Baker 6 , Benton J.Campbell 7 Jennifer Greenberg 8 ,Christopher Harris 9 ,and Miles Ruthberg 10 to be admitted pro hac vice on behalf of the Plaintiffs should be granted in association with local counsel, upon payment of the appropriate fee and registration for electronic filing as required by the Uniform Local Civil Rules of this Court.No further written order shall be issued by this Court. Signed by Magistrate Judge John M. Roper on June 27,2013 (Nicaud, Jenny) [Transferred from mssd on 10/23/2013.] (Entered: 06/27/2013)
11 MOTION to Change Venue MOTION to Dismiss by Signal International, LLC (Ungar, Hal). Added MOTION to Dismiss on 7/12/2013 (JCH). [Transferred from mssd on 10/23/2013.] (Entered: 07/11/2013)
12 MEMORANDUM in Support re 11 MOTION to Change Venue MOTION to Dismiss filed by Signal International, LLC (Attachments: # 1 Exhibit 1, # 2 Exhibit 2)(Ungar, Hal) [Transferred from mssd on 10/23/2013.] (Entered: 07/11/2013)
DOCKET ANNOTATION as to # 11. This document requests several motion reliefs. Every motion relief should be selected from the list of motion titles or each relief docketed separately. The same PDF document may be used for all motion filing entries. It is not necessary to refile as court staff has made the necessary correction. Attorney is advised to follow this procedure in future filings. DOCKET ANNOTATION as to # 12. L.U.Civ.R. 7(b)(2) requires that all supporting exhibits to a document be denominated by an exhibit letter or number and a meaningful description. Attorney is advised to follow this rule in future filings. (JCH) [Transferred from mssd on 10/23/2013.] (Entered: 07/12/2013)
13 MOTION to Change Venue /Transfer Pursuant to First−Filed Rule, MOTION to Dismiss For Failure to State a Claim Upon Which Relief Can Be Granted Pursuant to Rule 12(b)(6) by Signal International, Inc. (Ungar, Hal) [Transferred from mssd on 10/23/2013.] (Entered: 07/12/2013)

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07/12/2013 07/15/2013 07/15/2013 07/15/2013 07/15/2013 07/15/2013

14 MEMORANDUM in Support re 13 MOTION to Change Venue /Transfer Pursuant to First−Filed Rule MOTION to Dismiss For Failure to State a Claim Upon Which Relief Can Be Granted Pursuant to Rule 12(b)(6) filed by Signal International, Inc. (Ungar, Hal) [Transferred from mssd on 10/23/2013.] (Entered: 07/12/2013)
15 SUMMONS Returned Executed by Nandhakumar Nagaraj, Shahi Vijayan, Sunilkumar Marottikkal Kuttan, Rajankunju Geevarghese, Biju John, Lakshmanan Ponnayan Achari, Shanmugam Subramanian, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Ninan John Tharakan, Benny Kattukariyil Varkey, George Pulikkeparambil Varghese, Mookaparambil Itty Raveendranathan, Johny Mathew, Shaji Veluthalakuzhiy Nanoo, Shaiju Vadakkal George, Ranjit Singh, Mouleswararao Guntamukkala, Parshottam Ramchandra Mangani, John Yohannan, Jacob Mazhukkattu Mathew, Radhakrishna Pillai Sivarama Pillai, Kodakeril Baby Biji, Jomon George, Balwinder Singh, Aby Molathu Poulose, Joy Jacob, Sreenivasarao Raparthy, Mangalan Chandrasekharan Pillai, Appunni Arul Prakash, Shibu Joseph, Justin Poulose, Xavier Disoliyan Signal International, LLC served on 5/30/2013, answer due 7/11/2013. (Baker − PHV, H.) [Transferred from mssd on 10/23/2013.] (Entered: 07/15/2013)
16 SUMMONS Returned Executed by Nandhakumar Nagaraj, Shahi Vijayan, Sunilkumar Marottikkal Kuttan, Rajankunju Geevarghese, Biju John, Lakshmanan Ponnayan Achari, Shanmugam Subramanian, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Ninan John Tharakan, Benny Kattukariyil Varkey, George Pulikkeparambil Varghese, Mookaparambil Itty Raveendranathan, Johny Mathew, Shaji Veluthalakuzhiy Nanoo, Shaiju Vadakkal George, Ranjit Singh, Mouleswararao Guntamukkala, Parshottam Ramchandra Mangani, John Yohannan, Jacob Mazhukkattu Mathew, Radhakrishna Pillai Sivarama Pillai, Kodakeril Baby Biji, Jomon George, Balwinder Singh, Aby Molathu Poulose, Joy Jacob, Sreenivasarao Raparthy, Mangalan Chandrasekharan Pillai, Appunni Arul Prakash, Shibu Joseph, Justin Poulose, Xavier Disoliyan Signal International, Inc. served on 5/30/2013, answer due 6/20/2013. (Baker − PHV, H.) [Transferred from mssd on 10/23/2013.] (Entered: 07/15/2013)
17 SUMMONS Returned Executed by Nandhakumar Nagaraj, Shahi Vijayan, Sunilkumar Marottikkal Kuttan, Rajankunju Geevarghese, Biju John, Lakshmanan Ponnayan Achari, Shanmugam Subramanian, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Ninan John Tharakan, Benny Kattukariyil Varkey, George Pulikkeparambil Varghese, Mookaparambil Itty Raveendranathan, Johny Mathew, Shaji Veluthalakuzhiy Nanoo, Shaiju Vadakkal George, Ranjit Singh, Mouleswararao Guntamukkala, Parshottam Ramchandra Mangani, John Yohannan, Jacob Mazhukkattu Mathew, Radhakrishna Pillai Sivarama Pillai, Kodakeril Baby Biji, Jomon George, Balwinder Singh, Aby Molathu Poulose, Joy Jacob, Sreenivasarao Raparthy, Mangalan Chandrasekharan Pillai, Appunni Arul Prakash, Shibu Joseph, Justin Poulose, Xavier Disoliyan Michael Pol served on 6/7/2013, answer due 6/28/2013. (Baker − PHV, H.) [Transferred from mssd on 10/23/2013.] (Entered: 07/15/2013)
18 SUMMONS Returned Executed by Nandhakumar Nagaraj, Shahi Vijayan, Sunilkumar Marottikkal Kuttan, Rajankunju Geevarghese, Biju John, Lakshmanan Ponnayan Achari, Shanmugam Subramanian, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Ninan John Tharakan, Benny Kattukariyil Varkey, George Pulikkeparambil Varghese, Mookaparambil Itty Raveendranathan, Johny Mathew, Shaji Veluthalakuzhiy Nanoo, Shaiju Vadakkal George, Ranjit Singh, Mouleswararao Guntamukkala, Parshottam Ramchandra Mangani, John Yohannan, Jacob Mazhukkattu Mathew, Radhakrishna Pillai Sivarama Pillai, Kodakeril Baby Biji, Jomon George, Balwinder Singh, Aby Molathu Poulose, Joy Jacob, Sreenivasarao Raparthy, Mangalan Chandrasekharan Pillai, Appunni Arul Prakash, Shibu Joseph, Justin Poulose, Xavier Disoliyan Global Resources, Inc. served on 6/27/2013, answer due 7/18/2013. (Baker − PHV, H.) [Transferred from mssd on 10/23/2013.] (Entered: 07/15/2013)
19 SUMMONS Returned Executed by Nandhakumar Nagaraj, Shahi Vijayan, Sunilkumar Marottikkal Kuttan, Rajankunju Geevarghese, Biju John, Lakshmanan Ponnayan Achari, Shanmugam Subramanian, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Ninan John Tharakan, Benny Kattukariyil Varkey, George Pulikkeparambil Varghese, Mookaparambil Itty Raveendranathan, Johny Mathew, Shaji

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07/15/2013
07/15/2013
07/18/2013 07/19/2013 07/29/2013

Veluthalakuzhiy Nanoo, Shaiju Vadakkal George, Ranjit Singh, Mouleswararao Guntamukkala, Parshottam Ramchandra Mangani, John Yohannan, Jacob Mazhukkattu Mathew, Radhakrishna Pillai Sivarama Pillai, Kodakeril Baby Biji, Jomon George, Balwinder Singh, Aby Molathu Poulose, Joy Jacob, Sreenivasarao Raparthy, Mangalan Chandrasekharan Pillai, Appunni Arul Prakash, Shibu Joseph, Justin Poulose, Xavier Disoliyan Malvern C. Burnett served on 7/1/2013, answer due 7/22/2013. (Baker − PHV, H.) [Transferred from mssd on 10/23/2013.] (Entered: 07/15/2013)
20 SUMMONS Returned Executed by Nandhakumar Nagaraj, Shahi Vijayan, Sunilkumar Marottikkal Kuttan, Rajankunju Geevarghese, Biju John, Lakshmanan Ponnayan Achari, Shanmugam Subramanian, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Ninan John Tharakan, Benny Kattukariyil Varkey, George Pulikkeparambil Varghese, Mookaparambil Itty Raveendranathan, Johny Mathew, Shaji Veluthalakuzhiy Nanoo, Shaiju Vadakkal George, Ranjit Singh, Mouleswararao Guntamukkala, Parshottam Ramchandra Mangani, John Yohannan, Jacob Mazhukkattu Mathew, Radhakrishna Pillai Sivarama Pillai, Kodakeril Baby Biji, Jomon George, Balwinder Singh, Aby Molathu Poulose, Joy Jacob, Sreenivasarao Raparthy, Mangalan Chandrasekharan Pillai, Appunni Arul Prakash, Shibu Joseph, Justin Poulose, Xavier Disoliyan Law Offices of Malvern C. Burnett, A.P.C. served on 7/1/2013, answer due 7/22/2013. (Baker − PHV, H.) [Transferred from mssd on 10/23/2013.] (Entered: 07/15/2013)
21 SUMMONS Returned Executed by Nandhakumar Nagaraj, Shahi Vijayan, Sunilkumar Marottikkal Kuttan, Rajankunju Geevarghese, Biju John, Lakshmanan Ponnayan Achari, Shanmugam Subramanian, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Ninan John Tharakan, Benny Kattukariyil Varkey, George Pulikkeparambil Varghese, Mookaparambil Itty Raveendranathan, Johny Mathew, Shaji Veluthalakuzhiy Nanoo, Shaiju Vadakkal George, Ranjit Singh, Mouleswararao Guntamukkala, Parshottam Ramchandra Mangani, John Yohannan, Jacob Mazhukkattu Mathew, Radhakrishna Pillai Sivarama Pillai, Kodakeril Baby Biji, Jomon George, Balwinder Singh, Aby Molathu Poulose, Joy Jacob, Sreenivasarao Raparthy, Mangalan Chandrasekharan Pillai, Appunni Arul Prakash, Shibu Joseph, Justin Poulose, Xavier Disoliyan Gulf Coast Immigration Law Center, LLC served on 7/1/2013, answer due 7/22/2013. (Baker − PHV, H.) [Transferred from mssd on 10/23/2013.] (Entered: 07/15/2013)
22 MOTION for Extension of Time to Respond to Complaint by Malvern C. Burnett (Carlisle, Arthur) Modified to remove Ex Parte on 7/19/2013 (JCH). [Transferred from mssd on 10/23/2013.] (Entered: 07/18/2013)
DOCKET ANNOTATION as to # 22. Clerk has removed the Ex Parte verbiage from this docket entry and changed the security settings so the document is viewable for all parties. Documents that are filed Ex Parte are restricted and unable to be accessed by counsel of record. A Motion for Extension of Time to Answer should not be filed Ex Parte. (JCH) [Transferred from mssd on 10/23/2013.] (Entered: 07/19/2013)
23 RESPONSE in Opposition re 11 MOTION to Change Venue /Transfer, Pursuant to First−Filed Rule, and Pursuant to Rule 12(b)(6) to Dismiss For Failure to State a Claim Upon Which Relief Can Be Granted MOTION to Dismiss, 13 MOTION to Change Venue /Transfer Pursuant to First−Filed Rule MOTION to Dismiss For Failure to State a Claim Upon Which Relief Can Be Granted Pursuant to Rule 12(b)(6) filed by Lakshmanan Ponnayan Achari, Kodakeril Baby Biji, Xavier Disoliyan, Rajankunju Geevarghese, Jomon George, Shaiju Vadakkal George, Mouleswararao Guntamukkala, Joy Jacob, Biju John, Shibu Joseph, Sunilkumar Marottikkal Kuttan, Parshottam Ramchandra Mangani, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Jacob Mazhukkattu Mathew, Johny Mathew, Nandhakumar Nagaraj, Shaji Veluthalakuzhiy Nanoo, Mangalan Chandrasekharan Pillai, Radhakrishna Pillai Sivarama Pillai, Aby Molathu Poulose, Justin Poulose, Appunni Arul Prakash, Sreenivasarao Raparthy, Mookaparambil Itty Raveendranathan, Balwinder Singh, Ranjit Singh, Shanmugam Subramanian, Ninan John Tharakan, George Pulikkeparambil Varghese, Benny Kattukariyil Varkey, Shahi Vijayan, John Yohannan (Attachments: # 1 Exhibit A −− Excerpt of David v. Signal Compl., # 2 Exhibit B −− Signal Opp'n. to Class Cert. in David v. Signal, # 3 Exhibit C −− Excerpt of David v. Signal Third Am. Compl., # 4 Exhibit D −− Pol and Global Mot. to Dismiss in David v. Signal, # 5 Exhibit E −− Dewan and Dewan Consultants

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07/29/2013
07/31/2013 08/01/2013 08/01/2013
08/05/2013 08/06/2013

Mot. to Dismiss in David v. Signal, # 6 Exhibit F −− Order Denying Mots. to Dismiss in David v. Signal, # 7 Exhibit G −− Order Granting Mots. to Transfer in EEOC v. Signal, # 8 Exhibit H −− Signal Mot. to Partially Stay David v. Signal)(Baker − PHV, H.) [Transferred from mssd on 10/23/2013.] (Entered: 07/29/2013)
24 MEMORANDUM in Opposition re 11 MOTION to Change Venue /Transfer, Pursuant to First−Filed Rule, and Pursuant to Rule 12(b)(6) to Dismiss For Failure to State a Claim Upon Which Relief Can Be Granted MOTION to Dismiss, 13 MOTION to Change Venue /Transfer Pursuant to First−Filed Rule MOTION to Dismiss For Failure to State a Claim Upon Which Relief Can Be Granted Pursuant to Rule 12(b)(6) filed by Lakshmanan Ponnayan Achari, Kodakeril Baby Biji, Xavier Disoliyan, Rajankunju Geevarghese, Jomon George, Shaiju Vadakkal George, Mouleswararao Guntamukkala, Joy Jacob, Biju John, Shibu Joseph, Sunilkumar Marottikkal Kuttan, Parshottam Ramchandra Mangani, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Jacob Mazhukkattu Mathew, Johny Mathew, Nandhakumar Nagaraj, Shaji Veluthalakuzhiy Nanoo, Mangalan Chandrasekharan Pillai, Radhakrishna Pillai Sivarama Pillai, Aby Molathu Poulose, Justin Poulose, Appunni Arul Prakash, Sreenivasarao Raparthy, Mookaparambil Itty Raveendranathan, Balwinder Singh, Ranjit Singh, Shanmugam Subramanian, Ninan John Tharakan, George Pulikkeparambil Varghese, Benny Kattukariyil Varkey, Shahi Vijayan, John Yohannan (Baker − PHV, H.) [Transferred from mssd on 10/23/2013.] (Entered: 07/29/2013)
25 ANSWER to Complaint with Jury Demand by Malvern C. Burnett.(Carlisle, Arthur) [Transferred from mssd on 10/23/2013.] (Entered: 07/31/2013)
DOCKET ANNOTATION as to # 25. Pursuant to Fed.R.Cr.P. Rule 49(d) and Fed.R.Civ.P. Rule 84, appendix form 2 states that date, signature, address, e−mail address and telephone number are used at the conclusion of pleadings and other papers that require a signature. Document is undated (on respectfully submitted portion), but the date will be construed as the date of electronic filing. Attorney is advised to follow this rule in future filings. (JCH) [Transferred from mssd on 10/23/2013.] (Entered: 08/01/2013)
26 AMENDED COMPLAINT and Jury Demand against All Defendants, filed by Nandhakumar Nagaraj, Shahi Vijayan, Sunilkumar Marottikkal Kuttan, Rajankunju Geevarghese, Biju John, Lakshmanan Ponnayan Achari, Shanmugam Subramanian, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Ninan John Tharakan, Benny Kattukariyil Varkey, George Pulikkeparambil Varghese, Mookaparambil Itty Raveendranathan, Johny Mathew, Shaji Veluthalakuzhiy Nanoo, Shaiju Vadakkal George, Ranjit Singh, Mouleswararao Guntamukkala, Parshottam Ramchandra Mangani, John Yohannan, Jacob Mazhukkattu Mathew, Radhakrishna Pillai Sivarama Pillai, Kodakeril Baby Biji, Jomon George, Balwinder Singh, Aby Molathu Poulose, Joy Jacob, Sreenivasarao Raparthy, Mangalan Chandrasekharan Pillai, Appunni Arul Prakash, Shibu Joseph, Justin Poulose, Xavier Disoliyan, Estate of Kuliyanickal Paily Varghese, Eldose Isac, Savinder Singh, Thansilas Joseph, Varghese Varkey Abraham, Subhashithan Bahuleyan, Thenooran Kumaran Unnikrishnan, Kulath Somanathan Kalayam, Praveen Kulathum Muriyil Gopalakrishnan, Moni Panikulangara Thomas, Kittayi Sunil Kumar Therattil, Benny Chittilappilly Vareed, Nibu Raju, Bhaskaran Sreedharan Kutty.(Baker − PHV, H.) [Transferred from mssd on 10/23/2013.] (Entered: 08/01/2013)
27 Rebuttal re 24 Memorandum in Opposition to 11 Motion to Change Venue Motion to Dismiss 13 Motion to Change Venue Motion to Dismiss filed by Signal International, Inc., Signal International, LLC (Ungar, Hal) Modified to add links to motions on 8/6/2013 (JCH). [Transferred from mssd on 10/23/2013.] (Entered: 08/05/2013)
DOCKET ANNOTATION as to # 27. 1.) Incorrect linkage made. The Rebuttal should be linked to the Motion to Change Venue and the Motion to Dismiss. All related filings to motions (using the "Responses and Replies" category, with the exception of "Response to Order") should be linked back to the original motion. Court staff has made the correction. 2.) Pursuant to Fed.R.Cr.P. Rule 49(d) and Fed.R.Civ.P. Rule 84, appendix form 2 states that date, signature, address, e−mail address and telephone number are used at the conclusion of pleadings and other papers that require a signature. Document is undated (on respectfully submitted portion), but the date will be construed as the date of electronic filing. Attorney is advised to follow this rule in

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08/06/2013 08/07/2013
08/13/2013
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08/27/2013 08/30/2013 09/16/2013 09/20/2013

future filings. (JCH) [Transferred from mssd on 10/23/2013.] (Entered: 08/06/2013)
28 MOTION for Timothy W. Cerniglia to Appear Pro Hac Vice by Malvern C. Burnett (Carlisle, Arthur) [Transferred from mssd on 10/23/2013.] (Entered: 08/06/2013)
DOCKET ANNOTATION as to # 28. 1.) Incorrect form has been used. Attorney is referred to the Court's website, mssd.uscourts.gov, where official forms may be found. 2.) The Motion for Pro Hac and exhibits are filed as one main document. Exhibits should be scanned separately and docketed as properly identified attachments to the main document within the same docket entry. Attorney is directed to follow this procedure in future filings. L.U.Civ.R. 7.(b)(2). 3.) Pursuant to Fed.R.Cr.P. Rule 49(d) and Fed.R.Civ.P. Rule 84, appendix form 2 states that date, signature, address, e−mail address and telephone number are used at the conclusion of pleadings and other papers that require a signature. Document is undated (on respectfully submitted portion), but the date will be construed as the date of electronic filing. Attorney is advised to follow this rule in future filings. (JCH) [Transferred from mssd on 10/23/2013.] (Entered: 08/07/2013)
29 Rule 16(a) Initial Order: Telephonic Case Management Conference set for 10/17/2013 11:15 AM before Magistrate Judge John M. Roper. Confidential case memoranda to be submitted to Judge Roper via email to roper_chambers@mssd.uscourts.gov on or before one week prior to the conference. The CONFIDENTIAL case memoranda is NOT to be exchanged and will be viewed only by the Court. Also, by same deadline, counsel are to submit a joint proposed Case Management Order (form is attached as Exhibit A − do not complete pages 4 and 5) to same email address. Refer to attached for deadlines and instructions. (Attachments: # 1 Exhibit A − Blank Case Management Order, # 2 Exhibit B − Expedited Calendar, # 3 Exhibit C − Good Faith Certificate Form)(VLK) [Transferred from mssd on 10/23/2013.] (Entered: 08/13/2013)
TEXT ORDER ONLY The Court finds that the motion 28 of Timothy Cerniglia to be admitted pro hac vice on behalf of Malvern Burnett, the Law Offices of Malvern Burnett and Gulf Coast Immigration Law Center,L.L.C.should be granted in association with local counsel, upon payment of the appropriate fee and registration for electronic filing as required by this Court. No further written order shall be issued by this Court. Signed by Magistrate Judge John M. Roper on August 14,2013 (Nicaud, Jenny)[Transferred from mssd on 10/23/2013.] (Entered: 08/14/2013)
30 MOTION to Dismiss −− Motion of Plaintiffs First Named in the Amended Complaint to Dismiss Without Prejudice Their Claims Against Defendant Michael Pol by Varghese Varkey Abraham, Subhashithan Bahuleyan, Estate of Kuliyanickal Paily Varghese, Praveen Kulathum Muriyi Gopalakrishnan, Eldose Isac, Thansilas Joseph, Kulath Somanathan Kalayam, Bhaskaran Sreedharan Kutty, Nibu Raju, Savinder Singh, Kittayi Sunil Kumar Therattil, Moni Panikulangara Thomas, Thenooran Kumaran Unnikrishnan, Benny Chittilappilly Vareed (Attachments: # 1 Exhibit A − Notice of Chapter 7 Bankruptcy Case)(Baker − PHV, H.) [Transferred from mssd on 10/23/2013.] (Entered: 08/27/2013)
31 MEMORANDUM in Support re 30 MOTION to Dismiss −− Motion of Plaintiffs First Named in the Amended Complaint to Dismiss Without Prejudice Their Claims Against Defendant Michael Pol filed by Varghese Varkey Abraham, Subhashithan Bahuleyan, Estate of Kuliyanickal Paily Varghese, Praveen Kulathum Muriyi Gopalakrishnan, Eldose Isac, Thansilas Joseph, Kulath Somanathan Kalayam, Bhaskaran Sreedharan Kutty, Nibu Raju, Savinder Singh, Kittayi Sunil Kumar Therattil, Moni Panikulangara Thomas, Thenooran Kumaran Unnikrishnan, Benny Chittilappilly Vareed (Baker − PHV, H.) [Transferred from mssd on 10/23/2013.] (Entered: 08/27/2013)
Pro Hac Vice fee paid by Timothy W. Cerniglia $ 100, receipt number 14643004882. (JCH) [Transferred from mssd on 10/23/2013.] (Entered: 08/30/2013)
32 ORDER granting 30 Motion to Dismiss. Ordered that all claims asserted by the Amended Plaintiffs against Defendant Michael Pol in the Amended Complaint, Doc.No. 26, dated August 1, 2013, are dismissed without prejudice. Signed by Chief District Judge Louis Guirola, Jr on 9/16/13. (JCH) [Transferred from mssd on 10/23/2013.] (Entered: 09/16/2013)
33 MOTION to Consolidate Cases / For Limited Consolidation by Signal International, Inc., Signal International, LLC (Ungar, Hal) [Transferred from mssd on 10/23/2013.]

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10/07/2013
10/07/2013

(Entered: 09/20/2013)
34 MEMORANDUM in Support re 33 MOTION to Consolidate Cases / For Limited Consolidation filed by Signal International, Inc., Signal International, LLC (Ungar, Hal) [Transferred from mssd on 10/23/2013.] (Entered: 09/20/2013)
35 Emergency MOTION to Stay Proceedings by Signal International, Inc., Signal International, LLC (Ungar, Hal) [Transferred from mssd on 10/23/2013.] (Entered: 10/03/2013)
36 MEMORANDUM in Support re 35 Emergency MOTION to Stay Proceedings filed by Signal International, Inc., Signal International, LLC (Attachments: # 1 Exhibit 1 − (Doc. 1349) Order & Reasons, # 2 Exhibit 2 − (Doc. 1406) Order, # 3 Exhibit 3 − (Doc. 1380) Order & Reasons, # 4 Exhibit 4 − (Doc. 1391) Notice Regarding Plaintiffs' Proposed DPCMO, # 5 Exhibit 5 − (Doc. 1396) Signal's Opposition to Plaintiffs' Proposed DPCMO, # 6 Exhibit 6 − Affidavit of Erin Casey Hangartner, # 7 Exhibit 7 − (Doc. 1352) Order)(Ungar, Hal) [Transferred from mssd on 10/23/2013.] (Entered: 10/03/2013)
37 Response in Opposition re 33 MOTION to Consolidate Cases / For Limited Consolidation by Signal International, Inc., Signal International, LLC (Ungar, Hal) filed by Varghese Varkey Abraham, Lakshmanan Ponnayan Achari, Subhashithan Bahuleyan, Kodakeril Baby Biji, Xavier Disoliyan, Estate of Kuliyanickal Paily Varghese, Rajankunju Geevarghese, Jomon George, Shaiju Vadakkal George, Praveen Kulathum Muriyi Gopalakrishnan, Mouleswararao Guntamukkala, Eldose Isac, Raveendranathan Mookaparambil Itty, Joy Jacob, Biju John, Shibu Joseph, Thansilas Joseph, Kulath Somanathan Kalayam, Sunilkumar Marottikkal Kuttan, Bhaskaran Sreedharan Kutty, Parshottam Ramchandra Mangani, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Jacob Mazhukkattu Mathew, Johny Mathew, Nandhakumar Nagaraj, Shaji Veluthalakuzhiyil Nanoo, Mangalan Chandrasekharan Pillai, Radhakrishna Pillai Sivarama Pillai, Aby Molathu Poulose, Justin Poulose, Appunni Arul Prakash, Nibu Raju, Sreenivasarao Raparthy, Balwinder Singh, Ranjit Singh, Savinder Singh, Shanmugam Subramanian, Ninan John Tharakan, Kittayi Sunil Kumar Therattil, Moni Panikulangara Thomas, Thenooran Kumaran Unnikrishnan, Benny Chittilappilly Vareed, George Pulikkeparambil Varghese, Benny Kattukariyil Varkey, Shahi Vijayan, John Yohannan (Attachments: # 1 Exhibit A −− Excerpt of David v. Signal Compl., # 2 Exhibit B −− Excerpt of Signal Opp'n. to Class Cert. in David v. Signal, # 3 Exhibit C −− Excerpt of Chakkiyattil v. Signal Compl., # 4 Exhibit D −− Excerpt of Krishnakutty v. Signal Compl., # 5 Exhibit E −− Signal Mot. to Transfer in Chakkiyattil v. Signal, # 6 Exhibit F −− Signal Mot. to Transfer in Krishnakutty v. Signal, # 7 Exhibit G − Excerpt of Signal Mem. to Transfer in Krishnakutty v. Signal, # 8 Exhibit H −− Excerpt of David v. Signal Third Am. Compl.)(Adams − PHV, Daniel) [Transferred from mssd on 10/23/2013.] (Entered: 10/07/2013)
38 MEMORANDUM in Opposition re 33 MOTION to Consolidate Cases / For Limited Consolidation filed by Varghese Varkey Abraham, Lakshmanan Ponnayan Achari, Subhashithan Bahuleyan, Kodakeril Baby Biji, Xavier Disoliyan, Estate of Kuliyanickal Paily Varghese, Rajankunju Geevarghese, Jomon George, Shaiju Vadakkal George, Praveen Kulathum Muriyi Gopalakrishnan, Mouleswararao Guntamukkala, Eldose Isac, Raveendranathan Mookaparambil Itty, Joy Jacob, Biju John, Shibu Joseph, Thansilas Joseph, Kulath Somanathan Kalayam, Sunilkumar Marottikkal Kuttan, Bhaskaran Sreedharan Kutty, Parshottam Ramchandra Mangani, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Jacob Mazhukkattu Mathew, Johny Mathew, Nandhakumar Nagaraj, Shaji Veluthalakuzhiyil Nanoo, Mangalan Chandrasekharan Pillai, Radhakrishna Pillai Sivarama Pillai, Aby Molathu Poulose, Justin Poulose, Appunni Arul Prakash, Nibu Raju, Sreenivasarao Raparthy, Balwinder Singh, Ranjit Singh, Savinder Singh, Shanmugam Subramanian, Ninan John Tharakan, Kittayi Sunil Kumar Therattil, Moni Panikulangara Thomas, Thenooran Kumaran Unnikrishnan, Benny Chittilappilly Vareed, George Pulikkeparambil Varghese, Benny Kattukariyil Varkey, Shahi Vijayan, John Yohannan (Adams − PHV, Daniel) [Transferred from mssd on 10/23/2013.] (Entered: 10/07/2013)
39 MEMORANDUM in Opposition re 35 Emergency MOTION to Stay Proceedings filed by Varghese Varkey Abraham, Lakshmanan Ponnayan Achari, Subhashithan

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Bahuleyan, Kodakeril Baby Biji, Xavier Disoliyan, Estate of Kuliyanickal Paily Varghese, Rajankunju Geevarghese, Jomon George, Shaiju Vadakkal George, Praveen Kulathum Muriyi Gopalakrishnan, Mouleswararao Guntamukkala, Eldose Isac, Raveendranathan Mookaparambil Itty, Joy Jacob, Biju John, Shibu Joseph, Thansilas Joseph, Kulath Somanathan Kalayam, Sunilkumar Marottikkal Kuttan, Bhaskaran Sreedharan Kutty, Parshottam Ramchandra Mangani, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Jacob Mazhukkattu Mathew, Johny Mathew, Nandhakumar Nagaraj, Shaji Veluthalakuzhiyil Nanoo, Mangalan Chandrasekharan Pillai, Radhakrishna Pillai Sivarama Pillai, Aby Molathu Poulose, Justin Poulose, Appunni Arul Prakash, Nibu Raju, Sreenivasarao Raparthy, Balwinder Singh, Ranjit Singh, Savinder Singh, Shanmugam Subramanian, Ninan John Tharakan, Kittayi Sunil Kumar Therattil, Moni Panikulangara Thomas, Thenooran Kumaran Unnikrishnan, Benny Chittilappilly Vareed, George Pulikkeparambil Varghese, Benny Kattukariyil Varkey, Shahi Vijayan, John Yohannan (Adams − PHV, Daniel) [Transferred from mssd on 10/23/2013.] (Entered: 10/07/2013)
40 MOTION to Appoint Counsel / Enroll as Counsel, Alan D. Weinberger, by Signal International, Inc., Signal International, LLC (Ungar, Hal) [Transferred from mssd on 10/23/2013.] (Entered: 10/09/2013)
DOCKET ANNOTATION as to #40: Pursuant to Fed.R.Cr.P. Rule 49(d) and Fed.R.Civ.P. Rule 84, appendix form 2 states that date, signature, address, e−mail address and telephone number are used at the conclusion of pleadings and other papers that require a signature. Document is undated (on the respectfully submitted page), but the date will be construed as the date of electronic filing. Attorney is advised to follow this rule in future filings. (RLW) [Transferred from mssd on 10/23/2013.] (Entered: 10/10/2013)
41 REPLY to Response to Motion re 33 MOTION to Consolidate Cases / For Limited Consolidation filed by Signal International, Inc., Signal International, LLC (Ungar, Hal) [Transferred from mssd on 10/23/2013.] (Entered: 10/14/2013)
42 REPLY to Response to Motion re 35 Emergency MOTION to Stay Proceedings filed by Signal International, Inc., Signal International, LLC (Ungar, Hal) [Transferred from mssd on 10/23/2013.] (Entered: 10/14/2013)
TEXT ONLY ORDER STAYING PROCEEDINGS: This matter is before the Court on Motion to Stay Proceedings 35 , and being fully advised, the Court finds that the motion is well taken and is hereby granted. The proceedings in this case are stayed pending a decision on the Motion to Change Venue or Dismiss pending before the District Judge. No further written order shall be issued by the Court. Signed by Magistrate Judge John M. Roper on 10/16/2013 (VLK) [Transferred from mssd on 10/23/2013.] (Entered: 10/16/2013)
NOTICE of CANCELLED Calendar Setting: In light of the Text Only Order Staying Proceedings entered in this matter on 10/16/2013, the Telephonic Case Management Conference set for 10/31/2013 is hereby CANCELLED. (VLK) [Transferred from mssd on 10/23/2013.] (Entered: 10/16/2013)
43 ORDER CONSOLIDATING CASES: 1:13cv327 shall be consolidated with 1:13cv222. 1:13cv222LG−JMR shall serve as the lead case and all subsequent pleadings relating to either cause should be filed in the lead case only. Signed by Magistrate Judge Robert H. Walker on 10/17/2013 (wld) [Transferred from mssd on 10/23/2013.] (Entered: 10/18/2013)
TEXT ORDER ONLY Counsel has represented to this Court that he is withdrawing 40 Motion to Appoint Counsel. No further written order shall be issued by this Court. Signed by Magistrate Judge John M. Roper on October 18,2013 (Nicaud, Jenny) [Transferred from mssd on 10/23/2013.] (Entered: 10/18/2013)
44 ORDER granting 11 Motion to Change Venue. Consolidated cases are transferred to the US District Court for the Eastern District of Louisiana; and granting 33 Motion to Consolidate Cases. Civil Action Nos. 1:13cv318 and 1:13cv319 shall be consolidated, as member cases, with Civil Action No. 1:13cv222, which shall serve as the lead case. All subsequent pleadings relating to these causes of action should be filed in the LEAD case only. Signed by Chief District Judge Louis Guirola, Jr. on 10/18/13. (RLW) [Transferred from mssd on 10/23/2013.] (Entered: 10/18/2013)

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45 Case transferred in from District of Mississippi Southern; Case Number 1:13−cv−00222. Electronic file certified copy of transfer order and docket sheet received (jtd) (Entered: 10/23/2013)
46 NOTICE of Related Cases by Signal International, Inc., Signal International, LLC Pursuant to Local Rule 3.1. (Reference: 2:13−cv−06218, 2:13−CV−06219, 2:13−CV−06220, 2:13−CV−06221)(Ungar, Hal) Modified on 10/25/2013 (lag, ). (Entered: 10/24/2013)
47 ORDER TRANSFERRING CASE. Case transferred to Judge Susie Morgan and Magistrate Judge Daniel E. Knowles, III for all further proceedings. Judge Lance M Africk, Magistrate Judge Alma L. Chasez no longer assigned to case. Signed by Judge Lance M Africk on 10/24/2013. (NEF: Magistrate Judge Chasez)(Reference: ALL CASES)(blg) (Entered: 10/25/2013)
48 DEFICIENT** EXPARTE/CONSENT MOTION to Enroll as Counsel of Record Erin Casey Hangartner, Dominic J. Gianna, Alan Dean Weinberger, Elham R. Rabbani and Patricia A. Bollman by Signal International, Inc., Signal International, LLC. (Attachments: # 1 Proposed Order)(Reference: 2:13−cv−06218, 2:13−CV−06219, 2:13−CV−06220, 2:13−CV−06221)(Ungar, Hal) Modified on 10/28/2013 (gbw, ). (Entered: 10/25/2013)
49 EXPARTE/CONSENT MOTION to Enroll as Counsel of Record Erin Casey Hangartner, Dominic J. Gianna, Alan Dean Weinberger, Elham R. Rabbani and Patricia A. Bollman by Signal International, Inc., Signal International, LLC. (Attachments: # 1 Proposed Order)(Reference: 2:13−cv−06218, 2:13−CV−06219, 2:13−CV−06220, 2:13−CV−06221)(Ungar, Hal) (Entered: 10/28/2013)
50 DEFICIENT** EXPARTE/CONSENT MOTION to Appear as Counsel of Record by Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C.. (Attachments: # 1 Proposed Order)(Reference: 13−06219;13−06220;13−06221)(Cerniglia, Timothy) Modified on 10/29/2013 (gbw, ). (Entered: 10/28/2013)
51 EXPARTE/CONSENT MOTION to Withdraw Arthur D. Carlisle as Attorney by Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C.. (Attachments: # 1 Proposed Order)(Reference: 13−06219;13−06220;13−06221)(Cerniglia, Timothy) (Entered: 10/28/2013)
52 EXPARTE/CONSENT MOTION to Appear as Counsel of Record Daniel E. Buras, Jr. by Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C.. (Attachments: # 1 Proposed Order)(Reference: 13−06219; 13−06220; 13−06221)(Cerniglia, Timothy) (Entered: 10/29/2013)
53 ORDER granting 49 Motion to Enroll as Counsel of Record Erin Casey Hangartner, Dominic Joseph Gianna, Alan Dean Weinberger, Elham Rabbani, Patricia Anne F. Bollman for Signal International LLC and Signal International, Inc.. Signed by Judge Susie Morgan on 10/30/2013. (Reference: All cases)(gbw, ) (Entered: 10/31/2013)
54 ORDER granting 51 Motion to Withdraw as Attorney. Attorney Arthur D. Carlisle terminated for Defendants Malvern C. Burnett, Law Office of Malvern C. Burnett, APC, and Gulf Coast Immigration Center, LLC.. Signed by Judge Susie Morgan on 10/30/2013. (Reference: All cases)(gbw, ) (Entered: 10/31/2013)
55 ORDER granting 52 Motion to Appear As Co−counsel Daniel Edwin Buras, Jr for Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C.. Signed by Judge Susie Morgan on 10/30/2013. (Reference: All cases)(gbw, ) (Entered: 10/31/2013)
56 EXPARTE/CONSENT MOTION to Substitute Trial Attorney by Signal International, Inc., Signal International, LLC. (Attachments: # 1 Proposed Order)(Reference: 2:13−cv−06218, 2:13−CV−06219, 2:13−CV−06220, 2:13−CV−06221)(Hangartner, Erin) (Entered: 11/01/2013)
57 ORDER granting 56 Motion to Substitute. Signed by Judge Susie Morgan. (Reference: all)(cbn) (Entered: 11/05/2013)

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58 NOTICE of Voluntary Dismissal without prejudice as to Michael Pol by Varghese Kurisinkal Devassy, George Chacko Edavazhickal, Prasad Kunju Kunju, Ampattu Varughese Mathew, Anthony Sajan Oottuparambil Michael, Sivan Raghavan, Vijayanair Sankarapillai, Anil Scaria, Mandeep Singh, John Malakaran Thomas, Saju Christy Vallarian, Isaac Wilson Vazhikudilil, Benny Yohannan. (Reference: 2:13−cv−06221)(Grimsal, A.) (Entered: 11/07/2013)
59 RESPONSE/MEMORANDUM in Opposition re 106 Motion to Dismiss Doc. #23 in 13−6219 by George Paily Paulose Chakkiyattil, Chandrasekhara Pillai Rajesh Chemmanappilly, Sukumar Moses Dokka, Roy Punakkattu George, Radhakrishnan Kakkathiruthi, John Abraham Kalampukatt, Thomas Baby Madakkameprathu, Anthony Marian, Jacob Mathew, Shaju Olangattu Mathew, Davis Mathai Meledan, Jeegan Joseph Cheruthalakal Michael, Gopalakrishnan Unniampathu Vettical Nair, Prakash Kuttiyil Chandrasekharan Nair, Francis Kottackal Ouseph, Purayil Arjunan Padinhare, Sudheeran Panayamthatta, Telson Joseph Pazhampilly, Sreekumar Janardhanan Pillai, Pradeep Chembil Raman, Shawkat Ali Shaikh, Arunkumar Shaw Narayan Shaw, Subash Chandra Shukla, Ajith Chellayyan Swarnamma, Shibu Thankachan, Jaison Antony Thekkumpuram, Shajan Varghese, Thomas Varghese Vattakkattu (Reference: 2:13−cv−06219)(Grimsal, A.) Modified on 11/8/2013 (gbw, ). Modified on 11/15/2013 (gbw, ). (Entered: 11/07/2013)
60 EXPARTE/CONSENT MOTION to Appear Pro Hac Vice Eben P Colby (Filing fee $ 100 receipt number 053L−4223144) by George Paily Paulose Chakkiyattil, Chandrasekhara Pillai Rajesh Chemmanappilly, Sukumar Moses Dokka, Roy Punakkattu George, Radhakrishnan Kakkathiruthi, John Abraham Kalampukatt, Thomas Baby Madakkameprathu, Anthony Marian, Jacob Mathew, Shaju Olangattu Mathew, Davis Mathai Meledan, Jeegan Joseph Cheruthalakal Michael, Gopalakrishnan Unniampathu Vettical Nair, Prakash Kuttiyil Chandrasekharan Nair, Francis Kottackal Ouseph, Purayil Arjunan Padinhare, Sudheeran Panayamthatta, Telson Joseph Pazhampilly, Sreekumar Janardhanan Pillai, Pradeep Chembil Raman, Shawkat Ali Shaikh, Arunkumar Shaw Narayan Shaw, Subash Chandra Shukla, Ajith Chellayyan Swarnamma, Shibu Thankachan, Jaison Antony Thekkumpuram, Shajan Varghese, Thomas Varghese Vattakkattu. (Attachments: # 1 Exhibit Certificates of Good Standing, # 2 Exhibit Statement under Oath, # 3 Proposed Order, # 4 Exhibit ECF Form)(Reference: 2:13−cv−06219)Attorney A. Gregory Grimsal added to all plaintiffs).(Grimsal, A.) Modified on 11/8/2013 (gbw, ). (Entered: 11/07/2013)
61 EXPARTE/CONSENT MOTION to Appear Pro Hac Vice Peter Simhauser (Filing fee $ 100 receipt number 053L−4223202) by George Paily Paulose Chakkiyattil, Chandrasekhara Pillai Rajesh Chemmanappilly, Sukumar Moses Dokka, Roy Punakkattu George, Radhakrishnan Kakkathiruthi, John Abraham Kalampukatt, Thomas Baby Madakkameprathu, Anthony Marian, Jacob Mathew, Shaju Olangattu Mathew, Davis Mathai Meledan, Jeegan Joseph Cheruthalakal Michael, Gopalakrishnan Unniampathu Vettical Nair, Prakash Kuttiyil Chandrasekharan Nair, Francis Kottackal Ouseph, Purayil Arjunan Padinhare, Sudheeran Panayamthatta, Telson Joseph Pazhampilly, Sreekumar Janardhanan Pillai, Pradeep Chembil Raman, Shawkat Ali Shaikh, Arunkumar Shaw Narayan Shaw, Subash Chandra Shukla, Ajith Chellayyan Swarnamma, Shibu Thankachan, Jaison Antony Thekkumpuram, Shajan Varghese, Thomas Varghese Vattakkattu. (Attachments: # 1 Exhibit Certificate of Good Standing, # 2 Exhibit Declaration under Oath, # 3 Proposed Order, # 4 Exhibit ECF Form)(Reference: 2:13−cv−)6219)(Grimsal, A.) (Entered: 11/07/2013)
62 EXPARTE/CONSENT MOTION to Appear as Counsel of Record A. Gregory Grimsal and Steven W. Copley by Varghese Varkey Abraham, Lakshmanan Ponnayan Achari, Subhashithan Bahuleyan, Kodakeril Baby Biji, George Paily Paulose Chakkiyattil, Chandrasekhara Pillai Rajesh Chemmanappilly, Varghese Kurisinkal Devassy, Xavier Disoliyan, Sukumar Moses Dokka, George Chacko Edavazhickal, Thampy Putham Parambil Edicula, Rajankunju Geevarghese, Jomon George, Roy Punakkattu George, Shaiju Vadakkal George, Praveen Kulathum Muriyi Gopalakrishnan, Mouleswararao Guntamukkala, Eldose Isac, Joy Jacob, Biju John, Shibu Joseph, Thansilas Joseph, Radhakrishnan Kakkathiruthi, John Abraham Kalampukatt, Kulath Somanathan Kalayam, Sabu Puthukkuttumel Veede Krishnakutty, Prasad Kunju Kunju, Sunilkumar Marottikkal Kuttan, Bhaskaran Sreedharan Kutty, Thomas Baby Madakkameprathu, Parshottam Ramchandra Mangani, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Anthony Marian, Ampattu Varughese Mathew, Jacob Mazhukkattu Mathew, Jacob Mathew, Johny

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Mathew, Shaju Olangattu Mathew, Davis Mathai Meledan, Anthony Sajan Oottuparambil Michael, Jeegan Joseph Cheruthalakal Michael, Nandhakumar Nagaraj, Gopalakrishnan Unniampathu Vettical Nair, Prakash Kuttiyil Chandrasekharan Nair, Shaji Veluthalakuzhiyil Nanoo, Francis Kottackal Ouseph, Purayil Arjunan Padinhare, Sudheeran Panayamthatta, Telson Joseph Pazhampilly, Mangalan Chandrasekharan Pillai, Radhakrishna Pillai Sivarama Pillai, Sreekumar Janardhanan Pillai, Aby Molathu Poulose, Justin Poulose, Appunni Arul Prakash, Sivan Raghavan, Nibu Raju, Pradeep Chembil Raman, Sreenivasarao Raparthy, Mookaparambil Itty Raveendranathan, Vijayanair Sankarapillai, Anil Scaria, Shawkat Ali Shaikh, Arunkumar Shaw Narayan Shaw, Subash Chandra Shukla, Balwinder Singh, Mandeep Singh, Ranjit Singh, Savinder Singh, Shanmugam Subramanian, Ajith Chellayyan Swarnamma, Shibu Thankachan, Ninan John Tharakan, Jaison Antony Thekkumpuram, Kittayi Sunil Kumar Therattil, John Malakaran Thomas, Moni Panikulangara Thomas, Thenooran Kumaran Unnikrishnan, Saju Christy Vallarian, Benny Chittilappilly Vareed, George Pulikkeparambil Varghese, Kuliyanickal Paily Varghese, Shajan Varghese, Benny Kattukariyil Varkey, Thomas Varghese Vattakkattu, Isaac Wilson Vazhikudilil, Shahi Vijayan, Benny Yohannan, John Yohannan. (Attachments: # 1 Proposed Order)(Reference: 2:13−cv−06218; 2:13−cv−06219; 2:13−cv−06220; 2:13−cv−06221)Attorney A. Gregory Grimsal added to party Varghese Varkey Abraham, et al (pty:pla) .(Grimsal, A.) Modified on 11/12/2013 (gbw, ). (Entered: 11/08/2013)
63 ORDER: The Court will conduct a telephone Status Conference on 11/15/2013 04:00 PM to discuss discovery issues. The Court will provide the parties with call−in instructions. Signed by Judge Susie Morgan.(Reference: all)(cbn) (Entered: 11/08/2013)
64 EXPARTE/CONSENT MOTION to Appear Pro Hac Vice Scott W. Clark (Filing fee $ 100 receipt number 053L−4225667) by Thampy Putham Parambil Edicula, Sabu Puthukkuttumel Veede Krishnakutty. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Proposed Order)(Reference: 2:13−cv−06220)(Grimsal, A.) (Entered: 11/08/2013)
65 EXPARTE/CONSENT MOTION to Appear Pro Hac Vice John C. Low (Filing fee $ 100 receipt number 053L−4225706) by Thampy Putham Parambil Edicula, Sabu Puthukkuttumel Veede Krishnakutty. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Proposed Order)(Reference: 2:13−cv−06220)(Grimsal, A.) (Entered: 11/08/2013)
66 EXPARTE/CONSENT MOTION to Appear Pro Hac Vice Steven G. Spears (Filing fee $ 100 receipt number 053L−4225723) by Thampy Putham Parambil Edicula, Sabu Puthukkuttumel Veede Krishnakutty. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Proposed Order)(Reference: 2:13−cv−06220)(Grimsal, A.) (Entered: 11/08/2013)
67 EXPARTE/CONSENT MOTION to Appear Pro Hac Vice Daniel D. Adams (Filing fee $ 100 receipt number 053L−4225755) by Varghese Varkey Abraham, Lakshmanan Ponnayan Achari, Subhashithan Bahuleyan, Kodakeril Baby Biji, Xavier Disoliyan, Rajankunju Geevarghese, Jomon George, Shaiju Vadakkal George, Praveen Kulathum Muriyi Gopalakrishnan, Mouleswararao Guntamukkala, Eldose Isac, Joy Jacob, Biju John, Shibu Joseph, Thansilas Joseph, Kulath Somanathan Kalayam, Sunilkumar Marottikkal Kuttan, Bhaskaran Sreedharan Kutty, Parshottam Ramchandra Mangani, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Jacob Mazhukkattu Mathew, Johny Mathew, Nandhakumar Nagaraj, Shaji Veluthalakuzhiyil Nanoo, Mangalan Chandrasekharan Pillai, Radhakrishna Pillai Sivarama Pillai, Aby Molathu Poulose, Justin Poulose, Appunni Arul Prakash, Nibu Raju, Sreenivasarao Raparthy, Mookaparambil Itty Raveendranathan, Balwinder Singh, Ranjit Singh, Savinder Singh, Shanmugam Subramanian, Ninan John Tharakan, Kittayi Sunil Kumar Therattil, Moni Panikulangara Thomas, Thenooran Kumaran Unnikrishnan, Benny Chittilappilly Vareed, George Pulikkeparambil Varghese, Kuliyanickal Paily Varghese, Benny Kattukariyil Varkey, Shahi Vijayan, John Yohannan. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Proposed Order, # 4 Exhibit)(Reference: 2:13−cv−06218)(Grimsal, A.) (Entered: 11/08/2013)
68 EXPARTE/CONSENT MOTION to Appear Pro Hac Vice Jennifer Greenberg (Filing fee $ 100 receipt number 053L−4225757) by Varghese Varkey Abraham, Lakshmanan Ponnayan Achari, Subhashithan Bahuleyan, Kodakeril Baby Biji, Xavier Disoliyan, Rajankunju Geevarghese, Jomon George, Shaiju Vadakkal George, Praveen Kulathum Muriyi Gopalakrishnan, Mouleswararao Guntamukkala, Eldose Isac, Joy Jacob, Biju

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John, Shibu Joseph, Thansilas Joseph, Kulath Somanathan Kalayam, Sunilkumar Marottikkal Kuttan, Bhaskaran Sreedharan Kutty, Parshottam Ramchandra Mangani, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Jacob Mazhukkattu Mathew, Johny Mathew, Nandhakumar Nagaraj, Shaji Veluthalakuzhiyil Nanoo, Mangalan Chandrasekharan Pillai, Radhakrishna Pillai Sivarama Pillai, Aby Molathu Poulose, Justin Poulose, Appunni Arul Prakash, Nibu Raju, Sreenivasarao Raparthy, Mookaparambil Itty Raveendranathan, Balwinder Singh, Ranjit Singh, Savinder Singh, Shanmugam Subramanian, Ninan John Tharakan, Kittayi Sunil Kumar Therattil, Moni Panikulangara Thomas, Thenooran Kumaran Unnikrishnan, Benny Chittilappilly Vareed, George Pulikkeparambil Varghese, Kuliyanickal Paily Varghese, Benny Kattukariyil Varkey, Shahi Vijayan, John Yohannan. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Proposed Order, # 4 Exhibit Attorney Registration Form)(Reference: 2:13−cv−06218)(Grimsal, A.) (Entered: 11/08/2013)
69 DEFICIENT** EXPARTE/CONSENT MOTION to Appear Pro Hac Vice Christopher R. Harris (Filing fee $ 100 receipt number 053L−4225758) by Varghese Varkey Abraham, Lakshmanan Ponnayan Achari, Subhashithan Bahuleyan, Kodakeril Baby Biji, Xavier Disoliyan, Rajankunju Geevarghese, Jomon George, Shaiju Vadakkal George, Praveen Kulathum Muriyi Gopalakrishnan, Mouleswararao Guntamukkala, Eldose Isac, Joy Jacob, Biju John, Shibu Joseph, Thansilas Joseph, Kulath Somanathan Kalayam, Sunilkumar Marottikkal Kuttan, Bhaskaran Sreedharan Kutty, Parshottam Ramchandra Mangani, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Jacob Mazhukkattu Mathew, Johny Mathew, Nandhakumar Nagaraj, Shaji Veluthalakuzhiyil Nanoo, Mangalan Chandrasekharan Pillai, Radhakrishna Pillai Sivarama Pillai, Aby Molathu Poulose, Justin Poulose, Appunni Arul Prakash, Nibu Raju, Sreenivasarao Raparthy, Mookaparambil Itty Raveendranathan, Balwinder Singh, Ranjit Singh, Savinder Singh, Shanmugam Subramanian, Ninan John Tharakan, Kittayi Sunil Kumar Therattil, Moni Panikulangara Thomas, Thenooran Kumaran Unnikrishnan, Benny Chittilappilly Vareed, George Pulikkeparambil Varghese, Kuliyanickal Paily Varghese, Benny Kattukariyil Varkey, Shahi Vijayan, John Yohannan. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Proposed Order, # 4 Exhibit Attorney Registration Form)(Reference: 2:13−cv−06218)(Grimsal, A.) Modified on 11/12/2013 (gbw, ). (Entered: 11/08/2013)
70 EXPARTE/CONSENT MOTION to Appear Pro Hac Vice Miles N. Ruthberg (Filing fee $ 100 receipt number 053L−4225759) by Varghese Varkey Abraham, Lakshmanan Ponnayan Achari, Subhashithan Bahuleyan, Kodakeril Baby Biji, Xavier Disoliyan, Rajankunju Geevarghese, Jomon George, Shaiju Vadakkal George, Praveen Kulathum Muriyi Gopalakrishnan, Mouleswararao Guntamukkala, Eldose Isac, Joy Jacob, Biju John, Shibu Joseph, Thansilas Joseph, Kulath Somanathan Kalayam, Sunilkumar Marottikkal Kuttan, Bhaskaran Sreedharan Kutty, Parshottam Ramchandra Mangani, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Jacob Mazhukkattu Mathew, Johny Mathew, Nandhakumar Nagaraj, Shaji Veluthalakuzhiyil Nanoo, Mangalan Chandrasekharan Pillai, Radhakrishna Pillai Sivarama Pillai, Aby Molathu Poulose, Justin Poulose, Appunni Arul Prakash, Nibu Raju, Sreenivasarao Raparthy, Mookaparambil Itty Raveendranathan, Balwinder Singh, Ranjit Singh, Savinder Singh, Shanmugam Subramanian, Ninan John Tharakan, Kittayi Sunil Kumar Therattil, Moni Panikulangara Thomas, Thenooran Kumaran Unnikrishnan, Benny Chittilappilly Vareed, George Pulikkeparambil Varghese, Kuliyanickal Paily Varghese, Benny Kattukariyil Varkey, Shahi Vijayan, John Yohannan. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Proposed Order, # 4 Exhibit Attorney Registration Form)(Reference: 2:13−cv−06218)(Grimsal, A.) (Entered: 11/08/2013)
71 EXPARTE/CONSENT MOTION to Appear Pro Hac Vice Aaron M. Safane (Filing fee $ 100 receipt number 053L−4225760) by Varghese Varkey Abraham, Lakshmanan Ponnayan Achari, Subhashithan Bahuleyan, Kodakeril Baby Biji, Xavier Disoliyan, Rajankunju Geevarghese, Jomon George, Shaiju Vadakkal George, Praveen Kulathum Muriyi Gopalakrishnan, Mouleswararao Guntamukkala, Eldose Isac, Joy Jacob, Biju John, Shibu Joseph, Thansilas Joseph, Kulath Somanathan Kalayam, Sunilkumar Marottikkal Kuttan, Bhaskaran Sreedharan Kutty, Parshottam Ramchandra Mangani, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Jacob Mazhukkattu Mathew, Johny Mathew, Nandhakumar Nagaraj, Shaji Veluthalakuzhiyil Nanoo, Mangalan Chandrasekharan Pillai, Radhakrishna Pillai Sivarama Pillai, Aby Molathu Poulose, Justin Poulose, Appunni Arul Prakash, Nibu Raju, Sreenivasarao Raparthy, Mookaparambil Itty Raveendranathan, Balwinder Singh, Ranjit Singh, Savinder Singh,

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Shanmugam Subramanian, Ninan John Tharakan, Kittayi Sunil Kumar Therattil, Moni Panikulangara Thomas, Thenooran Kumaran Unnikrishnan, Benny Chittilappilly Vareed, George Pulikkeparambil Varghese, Kuliyanickal Paily Varghese, Benny Kattukariyil Varkey, Shahi Vijayan, John Yohannan. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Proposed Order, # 4 Exhibit Attorney Registration Form)(Reference: 2:13−cv−06218)(Grimsal, A.) (Entered: 11/08/2013)
72 EXPARTE/CONSENT MOTION to Appear Pro Hac Vice Michael Bhargava (Filing fee $ 100 receipt number 053L−4226042) by Varghese Kurisinkal Devassy, George Chacko Edavazhickal, Prasad Kunju Kunju, Ampattu Varughese Mathew, Anthony Sajan Oottuparambil Michael, Sivan Raghavan, Vijayanair Sankarapillai, Anil Scaria, Mandeep Singh, John Malakaran Thomas, Saju Christy Vallarian, Isaac Wilson Vazhikudilil, Benny Yohannan. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Proposed Order, # 4 Exhibit Attorney Registration Form)(Reference: 2:13−cv−06221)(Grimsal, A.) (Entered: 11/11/2013)
73 EXPARTE/CONSENT MOTION to Appear as Counsel of Record Daniele J. Capasso by Varghese Kurisinkal Devassy, George Chacko Edavazhickal, Prasad Kunju Kunju, Ampattu Varughese Mathew, Anthony Sajan Oottuparambil Michael, Sivan Raghavan, Vijayanair Sankarapillai, Anil Scaria, Mandeep Singh, John Malakaran Thomas, Saju Christy Vallarian, Isaac Wilson Vazhikudilil, Benny Yohannan. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Proposed Order, # 4 Exhibit Attorney Registration Form)(Reference: 2:13−cv−06221)(Grimsal, A.) (Entered: 11/11/2013)
74 EXPARTE/CONSENT MOTION to Appear as Counsel of Record Andrew C. Case by Varghese Kurisinkal Devassy, George Chacko Edavazhickal, Prasad Kunju Kunju, Ampattu Varughese Mathew, Anthony Sajan Oottuparambil Michael, Sivan Raghavan, Vijayanair Sankarapillai, Anil Scaria, Mandeep Singh, John Malakaran Thomas, Saju Christy Vallarian, Isaac Wilson Vazhikudilil, Benny Yohannan. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Proposed Order, # 4 Exhibit Attorney Registration Form)(Reference: 2:13−cv−06221)(Grimsal, A.) (Entered: 11/11/2013)
75 DEFICIENT** EXPARTE/CONSENT MOTION to Appear Pro Hac Vice Robert Fabrikant (Filing fee $ 100 receipt number 053L−4226049) by Varghese Kurisinkal Devassy, George Chacko Edavazhickal, Prasad Kunju Kunju, Ampattu Varughese Mathew, Anthony Sajan Oottuparambil Michael, Sivan Raghavan, Vijayanair Sankarapillai, Anil Scaria, Mandeep Singh, John Malakaran Thomas, Saju Christy Vallarian, Isaac Wilson Vazhikudilil, Benny Yohannan. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Proposed Order)(Reference: 2:13−cv−06221)(Grimsal, A.) Modified on 11/12/2013 (gbw, ). (Entered: 11/11/2013)
76 EXPARTE/CONSENT MOTION to Appear Pro Hac Vice Jeremy R. Lacks (Filing fee $ 100 receipt number 053L−4226056) by Varghese Kurisinkal Devassy, George Chacko Edavazhickal, Prasad Kunju Kunju, Ampattu Varughese Mathew, Anthony Sajan Oottuparambil Michael, Sivan Raghavan, Vijayanair Sankarapillai, Anil Scaria, Mandeep Singh, John Malakaran Thomas, Saju Christy Vallarian, Isaac Wilson Vazhikudilil, Benny Yohannan. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Proposed Order, # 4 Exhibit Attorney Registration Form)(Reference: 2:13−cv−06221)(Grimsal, A.) (Entered: 11/11/2013)
77 EXPARTE/CONSENT MOTION to Appear Pro Hac Vice Stephen T. Raptis (Filing fee $ 100 receipt number 053L−4226059) by Varghese Kurisinkal Devassy, George Chacko Edavazhickal, Prasad Kunju Kunju, Ampattu Varughese Mathew, Anthony Sajan Oottuparambil Michael, Sivan Raghavan, Vijayanair Sankarapillai, Anil Scaria, Mandeep Singh, John Malakaran Thomas, Saju Christy Vallarian, Isaac Wilson Vazhikudilil, Benny Yohannan. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Proposed Order, # 4 Exhibit Attorney Registration Form)(Reference: 2:13−cv−06221)(Grimsal, A.) (Entered: 11/11/2013)
78 ERROR: DUPLICATE DOCUMENT FILED** EXPARTE/CONSENT MOTION to Appear Pro Hac Vice Daniele J. Capasso (Filing fee $ 100 receipt number 053L−4226064) by Varghese Kurisinkal Devassy, George Chacko Edavazhickal, Prasad Kunju Kunju, Ampattu Varughese Mathew, Anthony Sajan Oottuparambil Michael, Sivan Raghavan, Vijayanair Sankarapillai, Anil Scaria, Mandeep Singh, John Malakaran Thomas, Saju Christy Vallarian, Isaac Wilson Vazhikudilil, Benny Yohannan. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Proposed Order, # 4 Exhibit

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Attorney Registration Form)(Reference: 2:13−CV−06221)(Grimsal, A.) Modified on 11/12/2013 (gbw, ). (Entered: 11/11/2013)
79 ERROR: DUPLICATE DOCUMENT FILED** EXPARTE/CONSENT MOTION to Appear Pro Hac Vice Andrew C. Case (Filing fee $ 100 receipt number 053L−4226068) by Varghese Kurisinkal Devassy, George Chacko Edavazhickal, Prasad Kunju Kunju, Ampattu Varughese Mathew, Anthony Sajan Oottuparambil Michael, Sivan Raghavan, Vijayanair Sankarapillai, Anil Scaria, Mandeep Singh, John Malakaran Thomas, Saju Christy Vallarian, Isaac Wilson Vazhikudilil, Benny Yohannan. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Proposed Order, # 4 Exhibit Attorney Registration Form)(Reference: 2:13−cv−06221)(Grimsal, A.) Modified on 11/12/2013 (gbw, ). (Entered: 11/11/2013)
80 EXPARTE/CONSENT MOTION to Appear Pro Hac Vice Benton J. Campbell (Filing fee $ 100 receipt number 053L−4226751) by Varghese Varkey Abraham, Lakshmanan Ponnayan Achari, Subhashithan Bahuleyan, Kodakeril Baby Biji, Xavier Disoliyan, Rajankunju Geevarghese, Jomon George, Shaiju Vadakkal George, Praveen Kulathum Muriyi Gopalakrishnan, Mouleswararao Guntamukkala, Eldose Isac, Joy Jacob, Biju John, Shibu Joseph, Thansilas Joseph, Kulath Somanathan Kalayam, Sunilkumar Marottikkal Kuttan, Bhaskaran Sreedharan Kutty, Parshottam Ramchandra Mangani, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Jacob Mazhukkattu Mathew, Johny Mathew, Nandhakumar Nagaraj, Shaji Veluthalakuzhiyil Nanoo, Mangalan Chandrasekharan Pillai, Radhakrishna Pillai Sivarama Pillai, Aby Molathu Poulose, Justin Poulose, Appunni Arul Prakash, Nibu Raju, Sreenivasarao Raparthy, Mookaparambil Itty Raveendranathan, Balwinder Singh, Ranjit Singh, Savinder Singh, Shanmugam Subramanian, Ninan John Tharakan, Kittayi Sunil Kumar Therattil, Moni Panikulangara Thomas, Thenooran Kumaran Unnikrishnan, Benny Chittilappilly Vareed, George Pulikkeparambil Varghese, Kuliyanickal Paily Varghese, Benny Kattukariyil Varkey, Shahi Vijayan, John Yohannan. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Proposed Order, # 4 Exhibit Attorney Registration Form)(Reference: 2:13−cv−06218)(Grimsal, A.) (Entered: 11/12/2013)
81 EXPARTE/CONSENT MOTION to Appear Pro Hac Vice Elizabeth C. Rowland (Filing fee $ 100 receipt number 053L−4226792) by Varghese Varkey Abraham, Lakshmanan Ponnayan Achari, Subhashithan Bahuleyan, Kodakeril Baby Biji, Xavier Disoliyan, Rajankunju Geevarghese, Jomon George, Shaiju Vadakkal George, Praveen Kulathum Muriyi Gopalakrishnan, Mouleswararao Guntamukkala, Eldose Isac, Joy Jacob, Biju John, Shibu Joseph, Thansilas Joseph, Kulath Somanathan Kalayam, Sunilkumar Marottikkal Kuttan, Bhaskaran Sreedharan Kutty, Parshottam Ramchandra Mangani, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Jacob Mazhukkattu Mathew, Johny Mathew, Nandhakumar Nagaraj, Shaji Veluthalakuzhiyil Nanoo, Mangalan Chandrasekharan Pillai, Radhakrishna Pillai Sivarama Pillai, Aby Molathu Poulose, Justin Poulose, Appunni Arul Prakash, Nibu Raju, Sreenivasarao Raparthy, Mookaparambil Itty Raveendranathan, Balwinder Singh, Ranjit Singh, Savinder Singh, Shanmugam Subramanian, Ninan John Tharakan, Kittayi Sunil Kumar Therattil, Moni Panikulangara Thomas, Thenooran Kumaran Unnikrishnan, Benny Chittilappilly Vareed, George Pulikkeparambil Varghese, Kuliyanickal Paily Varghese, Benny Kattukariyil Varkey, Shahi Vijayan, John Yohannan. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Proposed Order, # 4 Exhibit Attorney Registration Form)(Reference: 2:13−cv−06218)(Grimsal, A.) (Entered: 11/12/2013)
82 Correction of Docket Entry by Clerk re 62 MOTION to Appear as Counsel of Record A. Gregory Grimsal and Steven W. Copley. Document contains incorrect Section and/or Magistrate Judge. All future pleadings must reflect Section E and Magistrate Judge 3. (Reference: All Cases)(gbw, ) (Entered: 11/12/2013)
83 Correction of Docket Entry by Clerk re 79 MOTION to Appear Pro Hac Vice Andrew C. Case (Filing fee $ 100 receipt number 053L−4226068), 78 MOTION to Appear Pro Hac Vice Daniele J. Capasso (Filing fee $ 100 receipt number 053L−4226064). These are duplicate filing of documents #73 & #74 and will be noted as such. No further action is necessary. (Reference: 13−6221)(gbw, ) (Entered: 11/12/2013)
84 Correction of Docket Entry by Clerk re 64 MOTION to Appear Pro Hac Vice Scott W. Clark (Filing fee $ 100 receipt number 053L−4225667), 65 MOTION to Appear Pro Hac Vice John C. Low (Filing fee $ 100 receipt number 053L−4225706), 66 MOTION to Appear Pro Hac Vice Steven G. Spears (Filing fee $ 100 receipt number

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053L−4225723), 72 MOTION to Appear Pro Hac Vice Michael Bhargava (Filing fee $ 100 receipt number 053L−4226042), 73 MOTION to Appear as Counsel of Record Daniele J. Capasso, 74 MOTION to Appear as Counsel of Record Andrew C. Case, 76 MOTION to Appear Pro Hac Vice Jeremy R. Lacks (Filing fee $ 100 receipt number 053L−4226056), 77 MOTION to Appear Pro Hac Vice Stephen T. Raptis (Filing fee $ 100 receipt number 053L−4226059). All future documents filed must reflect the Master Case Caption, Master Case Number. Document must also state the case number in which the document applies or refers to by stating 'This document applies to (Case Number)' or REF: (Case Number)'. No further action is necessary. (Reference: 13−6220)(gbw, ) (Entered: 11/12/2013)
85 EXPARTE/CONSENT MOTION to Appear Pro Hac Vice Christopher R. Harris (Filing fee $ 100 receipt number 053L−4227264) by Varghese Varkey Abraham, Lakshmanan Ponnayan Achari, Subhashithan Bahuleyan, Kodakeril Baby Biji, Xavier Disoliyan, Rajankunju Geevarghese, Jomon George, Shaiju Vadakkal George, Praveen Kulathum Muriyi Gopalakrishnan, Mouleswararao Guntamukkala, Eldose Isac, Joy Jacob, Biju John, Shibu Joseph, Thansilas Joseph, Kulath Somanathan Kalayam, Sunilkumar Marottikkal Kuttan, Bhaskaran Sreedharan Kutty, Parshottam Ramchandra Mangani, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Jacob Mazhukkattu Mathew, Johny Mathew, Nandhakumar Nagaraj, Shaji Veluthalakuzhiyil Nanoo, Mangalan Chandrasekharan Pillai, Radhakrishna Pillai Sivarama Pillai, Aby Molathu Poulose, Justin Poulose, Appunni Arul Prakash, Nibu Raju, Sreenivasarao Raparthy, Mookaparambil Itty Raveendranathan, Balwinder Singh, Ranjit Singh, Savinder Singh, Shanmugam Subramanian, Ninan John Tharakan, Kittayi Sunil Kumar Therattil, Moni Panikulangara Thomas, Thenooran Kumaran Unnikrishnan, Benny Chittilappilly Vareed, George Pulikkeparambil Varghese, Kuliyanickal Paily Varghese, Benny Kattukariyil Varkey, Shahi Vijayan, John Yohannan. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Proposed Order, # 4 Exhibit Attorney Regisgration Form)(Reference: 2:13−cv−06218)(Grimsal, A.) (Entered: 11/12/2013)
86 RESPONSE/MEMORANDUM in Opposition filed by Varghese Kurisinkal Devassy, George Chacko Edavazhickal, Prasad Kunju Kunju, Ampattu Varughese Mathew, Anthony Sajan Oottuparambil Michael, Sivan Raghavan, Vijayanair Sankarapillai, Anil Scaria, Mandeep Singh, John Malakaran Thomas, Saju Christy Vallarian, Isaac Wilson Vazhikudilil, Benny Yohannan re 11 Burnett et al. Motion To Dismiss. (Reference: 13−6221)(Grimsal, A.) (Entered: 11/13/2013)
87 EXPARTE/CONSENT MOTION to Withdraw Motion To Strike by Varghese Kurisinkal Devassy, George Chacko Edavazhickal, Prasad Kunju Kunju, Ampattu Varughese Mathew, Anthony Sajan Oottuparambil Michael, Sivan Raghavan, Vijayanair Sankarapillai, Anil Scaria, Mandeep Singh, John Malakaran Thomas, Saju Christy Vallarian, Isaac Wilson Vazhikudilil, Benny Yohannan. (Attachments: # 1 Proposed Order)(Reference: 13−6221)(Grimsal, A.) (Entered: 11/13/2013)
88 EXPARTE/CONSENT MOTION to Appear Pro Hac Vice Robert Fabrikant (Filing fee $ 100 receipt number 053L−4229100) by Varghese Kurisinkal Devassy, George Chacko Edavazhickal, Prasad Kunju Kunju, Ampattu Varughese Mathew, Anthony Sajan Oottuparambil Michael, Sivan Raghavan, Vijayanair Sankarapillai, Anil Scaria, Mandeep Singh, John Malakaran Thomas, Saju Christy Vallarian, Isaac Wilson Vazhikudilil, Benny Yohannan. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Proposed Order)(Reference: 13−6221)(Grimsal, A.) (Entered: 11/13/2013)
89 ORDER granting 60 Motion to Appear Pro Hac Vice Eben Colby for plaintiffs. Signed by Judge Susie Morgan on 11/12/13. (Reference: 13−6219 plaintiffs)(jrc, ) (Entered: 11/13/2013)
90 ORDER granting 61 Motion to Appear Pro Hac Vice Peter Simshauser for plaintiffs. Signed by Judge Susie Morgan on 11/12/13. (Reference: 13−6219)(jrc, ) (Entered: 11/13/2013)
91 ORDER granting 62 Motion to Enroll Attorneys Steven W. Copley and Gregory Grimsal for plaintiffs. Signed by Judge Susie Morgan on 11/12/13. (Reference: 13−6218, 13−6219, 13−6220, 13−6221)(jrc, ) (Entered: 11/13/2013)
92 ORDER granting 64 Motion to Appear Pro Hac Vice John C. Low for plaintiffs. Signed by Judge Susie Morgan on 11/12/13. (Reference: 13−6220)(jrc, ) (Entered: 11/13/2013)

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93 ORDER granting 65 Motion to Appear Pro Hac Vice Scott W. Clark for plaintiffs. Signed by Judge Susie Morgan on 11/12/13. (Reference: 13−6220)(jrc, ) (Entered: 11/13/2013)
94 ORDER granting 66 Motion to Appear Pro Hac Vice Steven G. Spears for plaintiffs. Signed by Judge Susie Morgan. (Reference: 13−6220)(jrc, ) (Entered: 11/13/2013)
95 ORDER granting 67 Motion to Appear Pro Hac Vice Daniel D. Adams for the Achari plaintiffs. Signed by Judge Susie Morgan on 11/12/13. (Reference: 13−6218)(jrc, ) (Entered: 11/13/2013)
96 ORDER granting 68 Motion to Appear Pro Hac Vice Jennifer Greenberg for the Achari plaintiffs. Signed by Judge Susie Morgan on 11/12/13. (Reference: 13−6218)(jrc, ) (Entered: 11/13/2013)
97 ORDER granting 85 Motion to Appear Pro Hac Vice Christopher R. Harris for the Achari plaintiffs. Signed by Judge Susie Morgan on 11/12/13. (Reference: 13−6218)(jrc, ) (Entered: 11/13/2013)
98 ORDER granting 70 Motion to Appear Pro Hac Vice Miles Ruthberg for the Achari plaintiffs. Signed by Judge Susie Morgan on 11/12/13. (Reference: 13−6218)(jrc, ) (Entered: 11/13/2013)
99 ORDER granting 72 Motion to Appear Pro Hac Vice Michael Bhargava for the Devassy plaintiffs. Signed by Judge Susie Morgan on 11/12/13. (Reference: 13−6221)(jrc, ) (Entered: 11/13/2013)
100 ORDER granting 76 Motion to Appear Pro Hac Vice Jeremy Lacks for the Devassy plaintiffs. Signed by Judge Susie Morgan on 11/12/13. (Reference: 13−6221)(jrc, ) (Entered: 11/13/2013)
101 ORDER granting 77 Motion to Appear Pro Hac Vice Stephen Raptis for the Devassy plaintiffs. Signed by Judge Susie Morgan on 11/12/13. (Reference: 13−6221)(jrc, ) (Entered: 11/13/2013)
102 ORDER granting 71 Motion to Appear Pro Hac Vice Aaron M. Safane for the Achari plaintiffs. Signed by Judge Susie Morgan on 11/12/13. (Reference: 13−6218)(jrc, ) (Entered: 11/13/2013)
103 ORDER granting 73 Motion to Appear Pro Hac Vice Daniele J Capasso for Devassy plaintiffs. Signed by Judge Susie Morgan on 11/12/13. (Reference: 13−6221)(jrc, ) (Entered: 11/13/2013)
104 ORDER granting 74 Motion to Appear Pro Hac Vice Andrew Case for Devassy plaintiffs. Signed by Judge Susie Morgan on 11/12/13. (Reference: 13−6221)(jrc, ) (Entered: 11/13/2013)
105 ORDER granting 87 Motion to Withdraw Motion to Strike Motion to Dismiss (Doc. #18 in 13−6221). Signed by Judge Susie Morgan on 11/14/2013. (Reference: 13−6221)(gbw, ) (Entered: 11/14/2013)
106 MOTION to Dismiss for Failure to State a Claim by Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C.. (Attachments: # 1 Memorandum in Support)(Reference: 13−6219)[Transferred from mssd on 10/23/2013] (Originally Entered: 10/02/2013, Doc. #23)(gbw, ) (Entered: 11/15/2013)
108 Minute Entry for proceedings held before Judge Susie Morgan: Status Conference held on 11/15/2013. Status Conferences scheduled during 2014 in all Signal cases: 1/13/2014 12:00 PM, 4/30/2014 10:00 AM, 7/31/2014 2:00 PM, 10/30/2014 2:00 PM, and 12/17/2014 3:00 PM. Pretrial Conference in 08−1220 set for 12/17/2014 2:00 PM and Jury Trial (for the first 5 plaintiffs ONLY) set for 1/12/2015. Phase I trial in 12−557 set for 6/1/2015 09:00 AM. Parties are to comply with these and additional deadlines as set forth herein. (Reference: All Cases)(tsf) (Entered: 11/20/2013)
107 ORDER granting 88 Motion to Appear Pro Hac Vice. Signed by Judge Susie Morgan on 11/19/13. (Reference: 13−6221)(cbn) (Entered: 11/19/2013)

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11/20/2013 11/20/2013 11/20/2013 11/21/2013
11/21/2013 11/21/2013 11/22/2013 11/22/2013
11/22/2013
11/22/2013 11/25/2013

109 ORDER Telephone Status Conference set for 12/17/2013 12:00 PM. The Court will provide the parties with the call−in instructions. Signed by Judge Susie Morgan on 11/19/2013. (Reference: All Cases) (tsf) (Entered: 11/20/2013)
110 MOTION to Dismiss for Failure to State a Claim by Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C.. (Attachments: # 1 Memorandum in Support) (gbw, ). (Reference: 13−6220) [Transferred from mssd on 10/23/2013.] (Originally Entered: 10/02/2013, Doc. #16] (gbw, ). (Entered: 11/20/2013) (Entered: 11/20/2013)
111 RESPONSE/MEMORANDUM in Opposition filed by Thampy Putham Parambil Edicula, Sabu Puthukkuttumel Veede Krishnakutty re 110 MOTION to Dismiss for Failure to State a Claim . (Reference: 2:13−cv−06220)(Grimsal, A.) (Entered: 11/20/2013)
112 EXPARTE/CONSENT MOTION designation of A. Gregory Grimsal as Trial Attorney by Lakshmanan Ponnayan Achari, Kodakeril Baby Biji, Xavier Disoliyan, Rajankunju Geevarghese, Jomon George, Shaiju Vadakkal George, Mouleswararao Guntamukkala, Joy Jacob, Biju John, Shibu Joseph, Sunilkumar Marottikkal Kuttan, Parshottam Ramchandra Mangani, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Jacob Mazhukkattu Mathew, Johny Mathew, Nandhakumar Nagaraj, Mangalan Chandrasekharan Pillai, Radhakrishna Pillai Sivarama Pillai, Aby Molathu Poulose, Justin Poulose, Appunni Arul Prakash, Sreenivasarao Raparthy, Balwinder Singh, Ranjit Singh, Shanmugam Subramanian, Ninan John Tharakan, George Pulikkeparambil Varghese, Benny Kattukariyil Varkey, Shahi Vijayan, John Yohannan. (Attachments: # 1 Proposed Order)(Reference: 2:13−cv−06218)(Grimsal, A.) Modified on 11/22/2013 (plh, ). (Entered: 11/21/2013)
113 Summons Submitted for Issuance (Reference: 2:13−cv−06220)(Grimsal, A.) (Entered: 11/21/2013)
114 Summons Submitted for Issuance (Reference: 2:13−cv−06220)(Grimsal, A.) (Entered: 11/21/2013)
115 Summons Issued as to Indo−Amerisoft LLC((13−6220)), Kurella Rao. (Reference: 13−6220)(cms, ) (Additional attachment(s) added on 11/22/2013: # 1 Summons) (cms, ). (Entered: 11/22/2013)
116 EXPARTE/CONSENT MOTION designate A. Gregory Grimsal as Trial Attorney by Varghese Kurisinkal Devassy, George Chacko Edavazhickal, Prasad Kunju Kunju, Ampattu Varughese Mathew, Anthony Sajan Oottuparambil Michael, Sivan Raghavan, Vijayanair Sankarapillai, Anil Scaria, Mandeep Singh, John Malakaran Thomas, Saju Christy Vallarian, Isaac Wilson Vazhikudilil, Benny Yohannan. (Attachments: # 1 Proposed Order)(Reference: 2:13−cv−06221)(Grimsal, A.) Modified on 11/25/2013 (plh, ). (Entered: 11/22/2013)
117 EXPARTE/CONSENT MOTION Designation of Eben P. Colby as Trial Attorney by George Paily Paulose Chakkiyattil, Chandrasekhara Pillai Rajesh Chemmanappilly, Sukumar Moses Dokka, Roy Punakkattu George, Radhakrishnan Kakkathiruthi, John Abraham Kalampukatt, Thomas Baby Madakkameprathu, Anthony Marian, Jacob Mathew, Shaju Olangattu Mathew, Davis Mathai Meledan, Jeegan Joseph Cheruthalakal Michael, Gopalakrishnan Unniampathu Vettical Nair, Prakash Kuttiyil Chandrasekharan Nair, Francis Kottackal Ouseph, Purayil Arjunan Padinhare, Sudheeran Panayamthatta, Telson Joseph Pazhampilly, Sreekumar Janardhanan Pillai, Pradeep Chembil Raman, Shawkat Ali Shaikh, Arunkumar Shaw Narayan Shaw, Subash Chandra Shukla, Ajith Chellayyan Swarnamma, Shibu Thankachan, Jaison Antony Thekkumpuram, Shajan Varghese, Thomas Varghese Vattakkattu. (Attachments: # 1 Proposed Order)(Reference: 13−6219)(Colby, Eben) (Entered: 11/22/2013)
118 EXPARTE/CONSENT MOTION designate A. Gregory Grimsal as Trial Attorney by Thampy Putham Parambil Edicula, Sabu Puthukkuttumel Veede Krishnakutty. (Attachments: # 1 Proposed Order)(Reference: 2:13−cv−06220)(Grimsal, A.) Modified on 11/25/2013 (plh, ). (Entered: 11/22/2013)
119 Correction of Docket Entry by Clerk re 116 MOTION designate A. Gregory Grimsal as Trial Attorney, 117 MOTION Designation of Eben P. Colby as Trial Attorney and 118 MOTION designate A. Gregory Grimsal as Trial Attorney. The title of the

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11/25/2013 11/25/2013 11/25/2013 11/25/2013 11/25/2013 11/25/2013 11/25/2013 12/04/2013 12/04/2013
12/04/2013

attached proposed order should not include the word Proposed but only reflect Order on the actual document. (Reference: 13−6219, 13−6220 & 13−6221)(caa, ) (Entered: 11/25/2013)
120 Correction of Docket Entry by Clerk re 118 MOTION designate A. Gregory Grimsal as Trial Attorney , 116 MOTION designate A. Gregory Grimsal as Trial Attorney ; **Filing attorney incorrectly changed 'N' to 'Y' at the question 'Is this motion to be decided by the Magistrate Judge Y/N?'. This motion will be decided by the district judge. Clerk took corrective action.** (Reference: 13−6220; 13−6221)(plh, ) (Entered: 11/25/2013)
121 ORDER granting 80 Motion to Appear Pro Hac Vice. Signed by Judge Susie Morgan on 11/25/2013. (Reference: 13−6218)(caa, ) (Entered: 11/25/2013)
122 ORDER granting 81 Motion to Appear Pro Hac Vice as to Elizabeth C. Rowland. Signed by Judge Susie Morgan on 11/25/2013. (Reference: 13−6218)(caa, ) (Entered: 11/25/2013)
123 ORDER granting 112 Motion for designation of A. Gregory Grimsal as Trial Attorney. Signed by Judge Susie Morgan on 11/25/2013. (Reference: 13−6218)(caa, ) (Entered: 11/25/2013)
124 ORDER granting 116 Motion to designate A. Gregory Grimsal as Trial Attorney. Signed by Judge Susie Morgan on 11/25/2013. (Reference: 13−6221)(caa, ) (Entered: 11/25/2013)
125 ORDER granting 117 Motion for Designation of Eben P. Colby as Trial Attorney. Signed by Judge Susie Morgan on 11/25/2013. (Reference: 13−6219)(caa, ) (Entered: 11/26/2013)
126 ORDER granting 118 Motion to designate A. Gregory Grimsal as Trial Attorney. Signed by Judge Susie Morgan on 11/25/2013. (Reference: 13−6220)(caa, ) (Entered: 11/26/2013)
127 EXPARTE/CONSENT MOTION to Withdraw Justin B. Uhlemann as Attorney by Thampy Putham Parambil Edicula, Sabu Puthukkuttumel Veede Krishnakutty. (Attachments: # 1 Proposed Order)(Reference: 2:13−cv−06220)(Grimsal, A.) (Entered: 12/04/2013)
128 EXPARTE/CONSENT MOTION to Withdraw H. Gregory Baker as Attorney by Varghese Varkey Abraham, Lakshmanan Ponnayan Achari, Subhashithan Bahuleyan, Kodakeril Baby Biji, Xavier Disoliyan, Rajankunju Geevarghese, Jomon George, Shaiju Vadakkal George, Praveen Kulathum Muriyi Gopalakrishnan, Mouleswararao Guntamukkala, Eldose Isac, Joy Jacob, Biju John, Shibu Joseph, Thansilas Joseph, Kulath Somanathan Kalayam, Sunilkumar Marottikkal Kuttan, Bhaskaran Sreedharan Kutty, Parshottam Ramchandra Mangani, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Jacob Mazhukkattu Mathew, Johny Mathew, Nandhakumar Nagaraj, Shaji Veluthalakuzhiyil Nanoo, Mangalan Chandrasekharan Pillai, Radhakrishna Pillai Sivarama Pillai, Aby Molathu Poulose, Justin Poulose, Appunni Arul Prakash, Nibu Raju, Sreenivasarao Raparthy, Mookaparambil Itty Raveendranathan, Balwinder Singh, Ranjit Singh, Savinder Singh, Shanmugam Subramanian, Ninan John Tharakan, Kittayi Sunil Kumar Therattil, Moni Panikulangara Thomas, Thenooran Kumaran Unnikrishnan, Benny Chittilappilly Vareed, George Pulikkeparambil Varghese, Kuliyanickal Paily Varghese, Benny Kattukariyil Varkey, Shahi Vijayan, John Yohannan. (Attachments: # 1 Proposed Order)(Reference: 2:13−cv−06218)(Grimsal, A.) (Entered: 12/04/2013)
129 EXPARTE/CONSENT MOTION to Withdraw Jennifer Greenberg as Attorney by Varghese Varkey Abraham, Lakshmanan Ponnayan Achari, Subhashithan Bahuleyan, Kodakeril Baby Biji, Xavier Disoliyan, Rajankunju Geevarghese, Jomon George, Shaiju Vadakkal George, Praveen Kulathum Muriyi Gopalakrishnan, Mouleswararao Guntamukkala, Eldose Isac, Joy Jacob, Biju John, Shibu Joseph, Thansilas Joseph, Kulath Somanathan Kalayam, Sunilkumar Marottikkal Kuttan, Bhaskaran Sreedharan Kutty, Parshottam Ramchandra Mangani, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Jacob Mazhukkattu Mathew, Johny Mathew, Nandhakumar Nagaraj, Shaji Veluthalakuzhiyil Nanoo, Mangalan Chandrasekharan Pillai, Radhakrishna Pillai Sivarama Pillai, Aby Molathu Poulose, Justin Poulose, Appunni

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12/06/2013 12/10/2013 12/10/2013 12/16/2013
12/17/2013 12/17/2013 12/17/2013 12/19/2013

Arul Prakash, Nibu Raju, Sreenivasarao Raparthy, Mookaparambil Itty Raveendranathan, Balwinder Singh, Ranjit Singh, Savinder Singh, Shanmugam Subramanian, Ninan John Tharakan, Kittayi Sunil Kumar Therattil, Moni Panikulangara Thomas, Thenooran Kumaran Unnikrishnan, Benny Chittilappilly Vareed, George Pulikkeparambil Varghese, Kuliyanickal Paily Varghese, Benny Kattukariyil Varkey, Shahi Vijayan, John Yohannan. (Attachments: # 1 Proposed Order)(Reference: 2:13−cv−06218)(Grimsal, A.) (Entered: 12/04/2013)
130 NOTICE by Thampy Putham Parambil Edicula, Sabu Puthukkuttumel Veede Krishnakutty of Service Efforts on Kurella Rao and Indo−Ameri Soft L.L.C.. (Reference: 2:13−cv−06220)(Grimsal, A.) (Entered: 12/06/2013)
131 ORDER granting 128 Motion to Withdraw as Attorney. Attorney H. Gregory Baker terminated for Achari plaintiffs. Signed by Judge Susie Morgan on 12/10/2013. (Reference: 13−6218)(gbw, ) (Entered: 12/10/2013)
132 ORDER granting 129 Motion to Withdraw as Attorney. Attorney Jennifer Greenberg terminated for Achari plaintiffs. Signed by Judge Susie Morgan on 12/10/2013. (Reference: 13−6218)(gbw, ) (Entered: 12/10/2013)
133 RESPONSE/MEMORANDUM of Law in Opposition by Varghese Kurisinkal Devassy, George Chacko Edavazhickal, Prasad Kunju Kunju, Ampattu Varughese Mathew, Anthony Sajan Oottuparambil Michael, Sivan Raghavan, Vijayanair Sankarapillai, Anil Scaria, Mandeep Singh, John Malakaran Thomas, Saju Christy Vallarian, Isaac Wilson Vazhikudilil, Benny Yohannan re Signal Defendants' Motion to Transfer and Motion To Dismiss, docket # 13 in 13−6221) (Reference: 13−6221)(Bhargava, Michael) Modified on 12/17/2013 (gbw, ). (Entered: 12/16/2013)
134 Correction of Docket Entry by Clerk re 133 Brief. Filing attorney stated a Request for Oral Argument on this document. All Requests for oral argument must be filed as a separate document. (Reference: 13−6221)(gbw, ) (Entered: 12/17/2013)
135 EXPARTE/CONSENT MOTION to Permit Substitute TA to Attend 1/13/14 Status Conference by Plaintiffs (Attachments: # 1 Proposed Order)(Reference: 13−6218, 13−6221, 13−6220)(Grimsal, A.) Modified on 12/18/2013 (gbw, ). (Entered: 12/17/2013)
141 Minute Entry for proceedings held before Judge Susie Morgan: Telephone Status Conference held on 12/17/2013. (Reference: 13−6218; 13−6219; 13−6220; 13−6221)(plh, ) (Entered: 12/31/2013)
136 DEFICIENT** EXPARTE/CONSENT MOTION to Withdraw Robert B. McDuff, Sibyl C. Byrd, and Jacob W. Howard as Attorney by Varghese Varkey Abraham, Lakshmanan Ponnayan Achari, Subhashithan Bahuleyan, Kodakeril Baby Biji, George Paily Paulose Chakkiyattil, Chandrasekhara Pillai Rajesh Chemmanappilly, Varghese Kurisinkal Devassy, Xavier Disoliyan, Sukumar Moses Dokka, George Chacko Edavazhickal, Thampy Putham Parambil Edicula, Rajankunju Geevarghese, Jomon George, Roy Punakkattu George, Shaiju Vadakkal George, Praveen Kulathum Muriyi Gopalakrishnan, Mouleswararao Guntamukkala, Eldose Isac, Joy Jacob, Biju John, Shibu Joseph, Thansilas Joseph, Radhakrishnan Kakkathiruthi, John Abraham Kalampukatt, Kulath Somanathan Kalayam, Sabu Puthukkuttumel Veede Krishnakutty, Prasad Kunju Kunju, Sunilkumar Marottikkal Kuttan, Bhaskaran Sreedharan Kutty, Thomas Baby Madakkameprathu, Parshottam Ramchandra Mangani, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Anthony Marian, Ampattu Varughese Mathew, Jacob Mazhukkattu Mathew, Jacob Mathew, Johny Mathew, Shaju Olangattu Mathew, Davis Mathai Meledan, Anthony Sajan Oottuparambil Michael, Jeegan Joseph Cheruthalakal Michael, Nandhakumar Nagaraj, Gopalakrishnan Unniampathu Vettical Nair, Prakash Kuttiyil Chandrasekharan Nair, Shaji Veluthalakuzhiyil Nanoo, Francis Kottackal Ouseph, Purayil Arjunan Padinhare, Sudheeran Panayamthatta, Telson Joseph Pazhampilly, Mangalan Chandrasekharan Pillai, Radhakrishna Pillai Sivarama Pillai, Sreekumar Janardhanan Pillai, Aby Molathu Poulose, Justin Poulose, Appunni Arul Prakash, Sivan Raghavan, Nibu Raju, Pradeep Chembil Raman, Sreenivasarao Raparthy, Mookaparambil Itty Raveendranathan, Vijayanair Sankarapillai, Anil Scaria, Shawkat Ali Shaikh, Arunkumar Shaw Narayan Shaw, Subash Chandra Shukla, Balwinder Singh, Mandeep Singh, Ranjit Singh, Savinder Singh, Shanmugam Subramanian, Ajith Chellayyan Swarnamma, Shibu Thankachan, Ninan John Tharakan, Jaison Antony

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12/20/2013 12/27/2013 12/27/2013 12/27/2013 12/31/2013 01/02/2014
01/13/2014 01/17/2014
01/21/2014
01/21/2014 01/22/2014 01/22/2014

Thekkumpuram, Kittayi Sunil Kumar Therattil, John Malakaran Thomas, Moni Panikulangara Thomas, Thenooran Kumaran Unnikrishnan, Saju Christy Vallarian, Benny Chittilappilly Vareed, George Pulikkeparambil Varghese, Kuliyanickal Paily Varghese, Shajan Varghese, Benny Kattukariyil Varkey, Thomas Varghese Vattakkattu, Isaac Wilson Vazhikudilil, Shahi Vijayan, Benny Yohannan, John Yohannan. (Attachments: # 1 Proposed Order)(Reference: 2:13−cv−06218; 2:13−cv−06219: 2:13−cv−06220; 2:13−cv−06221)(Grimsal, A.) Modified on 12/20/2013 (gbw, ). (Entered: 12/19/2013)
137 EXPARTE/CONSENT MOTION to Withdraw Robert B. McDuff, Sibyl C. Byrd, and Jacob W. Howard as Attorneys by all plaintiffs (Attachments: # 1 Proposed Order)(Reference: 2:13−cv−06218; 2:13−cv−06219; 2:13−cv−06220; 2:13−cv−06221)(Grimsal, A.) Modified on 12/23/2013 (gbw, ). (Entered: 12/20/2013)
138 ORDER granting 127 Motion to Withdraw as Attorney. Attorney Justin B. Uhlemann terminated. Signed by Judge Susie Morgan on 12/27/2013. (Reference: 13−6220)(mmm) (Entered: 12/27/2013)
139 ORDER granting 137 Motion to Withdraw as Attorney. Attorney Robert McDuff terminated. Signed by Judge Susie Morgan on 12/27/2013. (Reference: All Cases)(mmm) (Entered: 12/27/2013)
140 ORDER granting 135 Motion Permit Substitute Trial Attorney to Attend 1/13/14 Status Conference. Signed by Judge Susie Morgan on 12/27/2013. (Reference: All Cases)(mmm) (Entered: 12/27/2013)
142 ANSWER to Complaint by Kurella Rao.(Reference: 13−6220)(gbw, ) (Entered: 01/02/2014)
143 NOTICE of Change of Address of Erin Casey Hangartner, Alan Dean Weinberger, Hal D. Ungar, and Elham R. Rabbani by Signal International, Inc., Signal International, LLC. (Reference: 2:13−cv−06218, 2:13−cv−06219, 2:13−cv−06220, 2:13−cv−06221)(Hangartner, Erin) Modified on 1/3/2014 (gbw, ). (Entered: 01/02/2014)
149 Minute Entry for proceedings held before Judge Susie Morgan: Status Conference held on 1/13/2014. Status Conference set for 2/21/2014 02:00 PM before Judge Susie Morgan. (Reference: All Cases)(bwn) (Entered: 01/23/2014)
144 MOTION for Protective Order by Plaintiffs. Motion(s) referred to Daniel E. Knowles, III. Motion set for 2/12/2014 11:00 AM before Magistrate Judge Daniel E. Knowles III. (Attachments: # 1 Memorandum in Support, # 2 Notice of Submission, # 3 Proposed Order, # 4 Affidavit)(Reference: 2:13−cv−06218; 2:13−cv−06219; 2:13−cv−06220; 2:13−cv−06221)(Grimsal, A.) Modified on 1/21/2014 to edit text (bwn). (Entered: 01/17/2014)
145 Correction of Docket Entry by Clerk re 144 MOTION for Protective Order − Filing attorney should have selected the correct hearing Judge.Clerk took corrective action to set motion for submission on 2/12/2014 at 11:00 a.m. before Magistrate Judge Knowles. No further action is necessary. (Reference: All Cases)(bwn) (Entered: 01/21/2014)
146 ORDER Setting ORAL Hearing on 144 MOTION for Protective Order : Motion set for ORAL HEARING on 2/12/2014 11:00 AM before Magistrate Judge Daniel E. Knowles III. Signed by Magistrate Judge Daniel E. Knowles, III on 1/21/14.(Reference: All Cases)(plh, ) (Entered: 01/21/2014)
147 RESPONSE/MEMORANDUM in Opposition filed by Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C. re 144 MOTION for Protective Order . (Reference: 13−6218;13−6219;13−6220)(Cerniglia, Timothy) (Entered: 01/22/2014)
148 MOTION to Dismiss for Failure to State a Claim by Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C.. Motion set for 2/12/2014 10:00 AM before Judge Susie Morgan. (Attachments: # 1 Memorandum in Support, # 2 Notice of Submission, # 3 Proposed Order)(Reference: 13−6218; 13−6219; 13−6220; 13−6221)(Cerniglia, Timothy) (Entered: 01/22/2014)

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01/23/2014
01/23/2014
01/27/2014 01/27/2014 01/28/2014 01/28/2014 01/29/2014 01/29/2014 01/30/2014 02/04/2014 02/04/2014 02/04/2014 02/04/2014
02/05/2014

150 MOTION to Dismiss (Partially) Complaints for Failure to State a Claim Upon Which Relief Can Be Granted by Signal International, Inc., Signal International, LLC. Motion set for 2/12/2014 10:00 AM before Judge Susie Morgan. (Attachments: # 1 Memorandum in Support, # 2 Notice of Submission)(Reference: 2:13−cv−06218, 2:13−cv−06219, 2:13−cv−06220, 2:13−cv−06221)(Hangartner, Erin) (Entered: 01/23/2014)
151 ORDER − IT IS ORDERED that plaintiffs' Motion for Protective Order (Doc. 144) be set before Judge Morgan. Any memorandum in opposition shall be filed by January 29, 2014. The Court has deemed oral argument unnecessary, as submission on the pleadings is sufficient.(Reference: 13cv6218, 13cv6219, 13cv6220, 13cv6221)(bwn) (Entered: 01/23/2014)
152 SUMMONS Returned Executed; Kurella Rao served on 12/12/2013, answer due 1/2/2014. (Reference: 2:13−cv−6218)(Low, John) (Entered: 01/27/2014)
153 SUMMONS Returned Executed; Indo−Amerisoft LLC((13−6220)) served on 12/12/2013, answer due 1/2/2014. (Reference: 2:13−cv−6218)(Low, John) (Entered: 01/27/2014)
154 DEFICIENT: SUMMONS Returned Executed; Kurella Rao served on 1/17/2014, answer due 2/7/2014. (Reference: 13−cv−6221)(Bhargava, Michael) Modified on 1/30/2014 (bwn). (Entered: 01/28/2014)
155 DEFICIENT: SUMMONS Returned Executed; Indo−Amerisoft LLC served on 1/14/2014, answer due 2/4/2014. (Reference: 13−cv−6221)(Bhargava, Michael) Modified on 1/30/2014 (bwn). (Entered: 01/28/2014)
156 NOTICE by All Plaintiffs of Joinder In Emergency Motion For Entry Of Order Regarding Protocol For Production Of Electronically Stored Information. (Reference: 13−6219; 13−6220; 13−6221)(Colby, Eben) (Entered: 01/29/2014)
157 ORDER Status Conference set for 2/6/2014 12:00 PM to discuss discovery issues with electronically stored information, as stated herein. Signed by Judge Susie Morgan on 1/29/2014. (Reference: All Cases) (tsf) (Entered: 01/29/2014)
158 RESPONSE/MEMORANDUM in Opposition filed by Signal International, Inc., Signal International, LLC re 144 MOTION for Protective Order . (Reference: 2:13−cv−06218, 2:13−cv−06219, 2:13−cv−06220, 2:13−cv−06221)(Hangartner, Erin) (Entered: 01/30/2014)
159 RESPONSE/MEMORANDUM in Opposition filed by All Plaintiffs re 150 MOTION to Dismiss (Partially) Complaints for Failure to State a Claim Upon Which Relief Can Be Granted . (Reference: 13−6218, 13−6219, 13−6220, 13−6221)(Raptis, Stephen) (Entered: 02/04/2014)
160 RESPONSE/MEMORANDUM in Opposition filed by All Plaintiffs re 148 MOTION to Dismiss for Failure to State a Claim . (Reference: 13−6219, 13−6220, 13−6221)(Colby, Eben) (Entered: 02/04/2014)
161 RESPONSE/MEMORANDUM in Opposition filed by Thampy Putham Parambil Edicula, Sabu Puthukkuttumel Veede Krishnakutty re 148 MOTION to Dismiss for Failure to State a Claim . (Reference: 2:13−cv−06220)(Grimsal, A.) (Entered: 02/04/2014)
162 Memorandum by Signal International, Inc., Signal International, LLC re 156 Notice (Other) Joinder in Emergency Motion for Entry of Order Regarding Protocol for Production of Electronically Stored Information (Attachments: # 1 Exhibit 1 − EEOC 12−12−13 letter, # 2 Exhibit 2 − SPLC 12−13−13 letter, # 3 Exhibit 3, # 4 Exhibit 4 − Excel spreadsheet, # 5 Exhibit 5 − Affidavit of Matthew Blonde)(Reference: 2:13−cv−06218, 2:13−cv−06219, 2:13−cv−06220, 2:13−cv−06221)(Hangartner, Erin) (Entered: 02/04/2014)
163 EXPARTE/CONSENT Consent MOTION for Leave to Supplement Exhibits re Doc. 1490 (08cv1220) by Signal International, Inc., Signal International, LLC. (Attachments: # 1 Proposed Order, # 2 Exhibit SIGE0057104−SIGE0057105)(Reference: 2:13−cv−06218, 2:13−cv−06219, 2:13−cv−06220, 2:13−cv−06221)(Hangartner, Erin) Modified on 2/6/2014 to edit text

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02/06/2014 02/06/2014 02/06/2014
02/07/2014
02/07/2014
02/10/2014 02/10/2014 02/11/2014 02/11/2014 02/11/2014 02/11/2014

(bwn). (Entered: 02/05/2014)
164 SUMMONS Returned Executed; Indo−Amerisoft LLC served on 1/14/2014, answer due 2/4/2014. (Reference: 13−6221)(Bhargava, Michael) Modified on 2/7/2014 to edit text (bwn). (Entered: 02/06/2014)
165 SUMMONS Returned Executed; Kurella Rao served on 1/17/2014, answer due 2/7/2014. (Reference: 13−6221)(Bhargava, Michael) Modified on 2/7/2014 to edit text (bwn). (Entered: 02/06/2014)
177 Minute Entry for proceedings held before Judge Susie Morgan: A status conference was held on February 6, 2014, at 12:00 p.m. in the chambers of Judge Susie Morgan. Counsel for the parties discussed the discovery issues and production of Electronically Stored Information (ESI) in EEOC v. Signal (12−557) (the "EEOC case"), David v. Signal (08−1220)(the "David case"), and Achari v. Signal (13−6218) (and all cases consolidated therewith) (the "Achari cases"). Parties are directed to comply with the dates set forth herein. The next in−person status conference will be held on February 21, 2014 at 4:00 p.m. in Judge Morgan's chambers. (Attachments: # 1 Exhibit A, # 2 Exhibit B) (tbl) [Docketed in 08−1220, 12−557, 13−6218 and its consolidated cases] (Entered: 02/14/2014)
166 DEFICIENT: EXPARTE/CONSENT MOTION to Appear Pro Hac Vice for Justin P. Aiello (Credit Card not accepted or unavailable − payment of filing fee due within 2 business days) by Thampy Putham Parambil Edicula, Sabu Puthukkuttumel Veede Krishnakutty. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Proposed Order)(Reference: 2:13−cv−06220)(Grimsal, A.) Modified on 2/7/2014 (bwn). (Entered: 02/07/2014)
167 DEFICIENT: EXPARTE/CONSENT MOTION to Appear Pro Hac Vice for Asra A. Chatham (Credit Card not accepted or unavailable − payment of filing fee due within 2 business days) by Thampy Putham Parambil Edicula, Sabu Puthukkuttumel Veede Krishnakutty. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Proposed Order)(Reference: 2:13−cv−06220)(Grimsal, A.) Modified on 2/7/2014 (bwn). (Entered: 02/07/2014)
Filing fee paid from Thampy Putham Parambil Edicula, Sabu Puthukkuttumel Veede Krishnakutty for Justin Aiello and Asra Chatham re 167 Motion to Appear Pro Hac Vice, 166 Motion to Appear Pro Hac Vice, (Filing fee $ 200) (Reference: 13−6220)(mmv, ) (Entered: 02/10/2014)
168 ORDER Telephone Status Conference set for Tuesday, February 11, 2014, at 10:00 a.m. The Court will provide the parties with the call−in instructions. Signed by Judge Susie Morgan on 2/10/2014. (Reference: All Cases) (tsf) (Entered: 02/10/2014)
169 EXPARTE/CONSENT MOTION to Appear Pro Hac Vice for Justin Paul Aiello (Fee previously paid) by Thampy Putham Parambil Edicula, Sabu Puthukkuttumel Veede Krishnakutty. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Proposed Order)(Reference: 2:13−cv−06220)(Grimsal, A.) (Entered: 02/11/2014)
170 EXPARTE/CONSENT MOTION to Appear Pro Hac Vice for Asra Annette Chatham (Fee previously paid) by Thampy Putham Parambil Edicula, Sabu Puthukkuttumel Veede Krishnakutty. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Proposed Order)(Reference: 2:13−cv−06220)(Grimsal, A.) (Entered: 02/11/2014)
171 EXPARTE/CONSENT Consent MOTION for Leave to File Reply Memorandum Supporting Signal's Motion to Dismiss The Complaints Partially For Failure to State a Claim by Signal International, Inc., Signal International, LLC. (Attachments: # 1 Proposed Order, # 2 Proposed Pleading)(Reference: 2:13−cv−06218, 2:13−cv−06219, 2:13−cv−06220, 2:13−cv−06221)(Hangartner, Erin) (Entered: 02/11/2014)
172 Minute Entry for proceedings held before Judge Susie Morgan: Status Conference held on 2/11/2014. The Court granted Signal's request to depose plaintiff Jacob Joseph Kaddakkarappally for four (4) days. The Court ordered Signal to pay the costs associated with changing the witness' flights. The Court will hold an additional telephone status conference on February 13, 2014 at 2:00 p.m. The Court ordered Signal to file its answer by Monday, February 17, 2014. (Reference: All Cases)(bwn) (Entered: 02/12/2014)

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02/12/2014 02/12/2014 02/12/2014 02/13/2014 02/13/2014
02/13/2014 02/14/2014
02/14/2014 02/14/2014 02/17/2014

173 ORDER granting 169 Motion to Appear Pro Hac Vice as to Justin P. Aiello. Signed by Judge Susie Morgan on 2/12/2014. (Reference: 2:13cv6220)(bwn) (Entered: 02/13/2014)
175 ORDER granting 171 Motion for Leave to File Reply Memorandum Supporting Signal's Motion to Dismiss The Complaints Partially For Failure to State a Claim. Signed by Judge Susie Morgan on 2/12/2014. (Reference: All Cases)(bwn) (Entered: 02/13/2014)
176 REPLY to Response to Motion in Support filed by Signal International, Inc., Signal International, LLC re 150 MOTION to Dismiss (Partially) Complaints for Failure to State a Claim Upon Which Relief Can Be Granted. (Reference: All Cases)(bwn) (Entered: 02/13/2014)
174 ORDER granting 170 Motion to Appear Pro Hac Vice as to Asra Chatham. Signed by Judge Susie Morgan on 2/12/2014. (Reference: 2:13cv6220)(bwn) (Entered: 02/13/2014)
178 Minute Entry for proceedings held before Judge Susie Morgan: A status conference was held on February 13, 2014, at 2:00 p.m. in the chambers of Judge Susie Morgan. Counsel for the parties discussed the discovery issues and production of Electronically Stored Information (ESI) in EEOC v. Signal (12−557) (the "EEOC case"), David v. Signal (08−1220)(the "David case"), and Achari v. Signal (13−6218) (and all cases consolidated therewith) (the "Achari cases"). Parties are directed to comply with the deadlines/schedule set forth herein. (tbl) [Docketed in 08−1220, 12−557, 13−6218 and its consolidated cases] (Entered: 02/14/2014)
195 MOTION to Dismiss Action by J&M Associates, Inc. of Mississippi, J&M Marine & Industrial, LLC, Billy R Wilks. Motion set for 3/26/2014 10:00 AM before Judge Susie Morgan. (Attachments: # 1 Proposed Order)(Reference: All Cases)(bwn) (Entered: 02/27/2014)
179 EXPARTE/CONSENT MOTION to Appear Pro Hac Vice for Craig A. Batchelor (Filing fee $ 100 receipt number 053L−4345963) by Lakshmanan Ponnayan Achari, Kodakeril Baby Biji, Xavier Disoliyan, Rajankunju Geevarghese, Jomon George, Shaiju Vadakkal George, Praveen Kulathum Muriyi Gopalakrishnan, Mouleswararao Guntamukkala, Eldose Isac, Joy Jacob, Biju John, Shibu Joseph, Thansilas Joseph, Kulath Somanathan Kalayam, Sunilkumar Marottikkal Kuttan, Bhaskaran Sreedharan Kutty, Parshottam Ramchandra Mangani, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Jacob Mazhukkattu Mathew, Johny Mathew, Nandhakumar Nagaraj, Shaji Veluthalakuzhiyil Nanoo, Mangalan Chandrasekharan Pillai, Radhakrishna Pillai Sivarama Pillai, Aby Molathu Poulose, Justin Poulose, Appunni Arul Prakash, Nibu Raju, Sreenivasarao Raparthy, Mookaparambil Itty Raveendranathan, Balwinder Singh, Ranjit Singh, Savinder Singh, Shanmugam Subramanian, Ninan John Tharakan, Kittayi Sunil Kumar Therattil, Moni Panikulangara Thomas, Thenooran Kumaran Unnikrishnan, Benny Chittilappilly Vareed, George Pulikkeparambil Varghese, Kuliyanickal Paily Varghese, Benny Kattukariyil Varkey, Shahi Vijayan, John Yohannan. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Proposed Order)(Reference: 2:13−cv−06218)(Grimsal, A.) (Entered: 02/14/2014)
180 EXPARTE/CONSENT MOTION to Appear Pro Hac Vice for Robert M. Kline (Credit Card not accepted or unavailable − payment of filing fee due within 2 business days) by Thampy Putham Parambil Edicula, Sabu Puthukkuttumel Veede Krishnakutty. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Proposed Order)(Reference: 2:13−cv−06220)(Grimsal, A.) (Attachment 3 replaced on 2/18/2014) (bwn). (Entered: 02/14/2014)
181 EXPARTE/CONSENT MOTION to Appear Pro Hac Vice for Marissa C. Krumm (Credit Card not accepted or unavailable − payment of filing fee due within 2 business days) by Thampy Putham Parambil Edicula, Sabu Puthukkuttumel Veede Krishnakutty. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Proposed Order)(Reference: 2:13−cv−06220)(Grimsal, A.) (Attachment 3 replaced on 2/18/2014) (bwn). (Entered: 02/14/2014)
182 ORDER that plaintiffs shall file an amended complaint no later than MONDAY, FEBRUARY 24, 2014, as stated herein. Signed by Judge Susie Morgan on 2/17/2014.

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02/20/2014

(Reference: ALL CASES) (tsf) (Entered: 02/17/2014)
183 PROTECTIVE ORDER. Signed by Judge Susie Morgan on 2/17/2014. (Reference: ALL CASES) (tsf) (Entered: 02/17/2014)
184 Correction of Docket Entry by Clerk re 181 MOTION to Appear Pro Hac Vice for Marissa C. Krumm, 180 MOTION to Appear Pro Hac Vice for Robert M. Kline − **Filing fee is DUE. Please use the event under 'Other Documents − Filing Fee Payment − Appear Pro Hac Vice' and use a credit card to pay this fee. This event must be entered for each attorney seeking to appear Pro Hac Vice. In the future, this fee should be paid when the motion is filed.** (Reference: 2:13cv6220)(bwn) (Entered: 02/18/2014)
185 CLAWBACK ORDER. Signed by Judge Susie Morgan on 2/14/2014.(Reference: All Cases)(bwn) (Entered: 02/18/2014)
Filing fee paid from Thampy Putham Parambil Edicula, Sabu Puthukkuttumel Veede Krishnakutty for Robert M. Kline re 180 Motion to Appear Pro Hac Vice, (Filing fee $ 100) (Reference: 13−6220)(mmv, ) (Entered: 02/18/2014)
Filing fee paid from Thampy Putham Parambil Edicula, Sabu Puthukkuttumel Veede Krishnakutty for Marissa C. Krumm re 181 Motion to Appear Pro Hac Vice, (Filing fee $ 100) (Reference: 13−6220)(mmv, ) (Entered: 02/18/2014)
186 ORDER granting 179 Motion to Appear Pro Hac Vice as to Attorney Craig Batchelor. Signed by Judge Susie Morgan. (Reference: 13cv6218)(bwn) (Entered: 02/18/2014)
187 ORDER Regarding Protocols for the Production of Electronically Stored Information. Signed by Judge Susie Morgan. (Attachments: # 1 List of Custodians)(Reference: All Cases)(bwn) (Entered: 02/19/2014)
188 EXPARTE/CONSENT MOTION to Expedite Motion for Extension of Time to Amend Complaint by Varghese Varkey Abraham, Lakshmanan Ponnayan Achari, Subhashithan Bahuleyan, Kodakeril Baby Biji, George Paily Paulose Chakkiyattil, Chandrasekhara Pillai Rajesh Chemmanappilly, Varghese Kurisinkal Devassy, Xavier Disoliyan, Sukumar Moses Dokka, George Chacko Edavazhickal, Thampy Putham Parambil Edicula, Rajankunju Geevarghese, Jomon George, Roy Punakkattu George, Shaiju Vadakkal George, Praveen Kulathum Muriyi Gopalakrishnan, Mouleswararao Guntamukkala, Eldose Isac, Joy Jacob, Biju John, Shibu Joseph, Thansilas Joseph, Kulath Somanathan Kalayam, Sabu Puthukkuttumel Veede Krishnakutty, Prasad Kunju Kunju, Sunilkumar Marottikkal Kuttan, Bhaskaran Sreedharan Kutty, Thomas Baby Madakkameprathu, Parshottam Ramchandra Mangani, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Anthony Marian, Ampattu Varughese Mathew, Jacob Mazhukkattu Mathew, Jacob Mathew, Johny Mathew, Shaju Olangattu Mathew, Davis Mathai Meledan, Anthony Sajan Oottuparambil Michael, Jeegan Joseph Cheruthalakal Michael, Nandhakumar Nagaraj, Gopalakrishnan Unniampathu Vettical Nair, Prakash Kuttiyil Chandrasekharan Nair, Shaji Veluthalakuzhiyil Nanoo, Francis Kottackal Ouseph, Purayil Arjunan Padinhare, Sudheeran Panayamthatta, Telson Joseph Pazhampilly, Mangalan Chandrasekharan Pillai, Radhakrishna Pillai Sivarama Pillai, Sreekumar Janardhanan Pillai, Aby Molathu Poulose, Justin Poulose, Appunni Arul Prakash, Sivan Raghavan, Nibu Raju, Pradeep Chembil Raman, Sreenivasarao Raparthy, Mookaparambil Itty Raveendranathan, Vijayanair Sankarapillai, Anil Scaria, Shawkat Ali Shaikh, Arunkumar Shaw Narayan Shaw, Subash Chandra Shukla, Balwinder Singh, Mandeep Singh, Ranjit Singh, Savinder Singh, Shanmugam Subramanian, Ajith Chellayyan Swarnamma, Shibu Thankachan, Ninan John Tharakan, Jaison Antony Thekkumpuram, Kittayi Sunil Kumar Therattil, John Malakaran Thomas, Moni Panikulangara Thomas, Thenooran Kumaran Unnikrishnan, Saju Christy Vallarian, Benny Chittilappilly Vareed, George Pulikkeparambil Varghese, Kuliyanickal Paily Varghese, Shajan Varghese, Benny Kattukariyil Varkey, Thomas Varghese Vattakkattu, Isaac Wilson Vazhikudilil, Shahi Vijayan, Benny Yohannan, John Yohannan. (Attachments: # 1 Proposed Order)(Reference: 2:13−cv−06218; 2:13−cv−06219; 2:13−cv−06220; 2:13−cv−06221)(Grimsal, A.) (Entered: 02/20/2014)
189 EXPARTE/CONSENT MOTION for Extension of Time to Amend Complaint by Varghese Varkey Abraham, Lakshmanan Ponnayan Achari, Subhashithan Bahuleyan, Kodakeril Baby Biji, George Paily Paulose Chakkiyattil, Chandrasekhara Pillai Rajesh

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02/20/2014 02/20/2014 02/21/2014
02/21/2014 02/21/2014 02/24/2014 02/28/2014 02/28/2014 03/03/2014

Chemmanappilly, Varghese Kurisinkal Devassy, Xavier Disoliyan, Sukumar Moses Dokka, George Chacko Edavazhickal, Thampy Putham Parambil Edicula, Rajankunju Geevarghese, Jomon George, Roy Punakkattu George, Shaiju Vadakkal George, Praveen Kulathum Muriyi Gopalakrishnan, Mouleswararao Guntamukkala, Eldose Isac, Joy Jacob, Biju John, Shibu Joseph, Thansilas Joseph, Radhakrishnan Kakkathiruthi, John Abraham Kalampukatt, Kulath Somanathan Kalayam, Sabu Puthukkuttumel Veede Krishnakutty, Prasad Kunju Kunju, Sunilkumar Marottikkal Kuttan, Bhaskaran Sreedharan Kutty, Thomas Baby Madakkameprathu, Parshottam Ramchandra Mangani, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Anthony Marian, Ampattu Varughese Mathew, Jacob Mazhukkattu Mathew, Jacob Mathew, Johny Mathew, Shaju Olangattu Mathew, Davis Mathai Meledan, Anthony Sajan Oottuparambil Michael, Jeegan Joseph Cheruthalakal Michael, Nandhakumar Nagaraj, Gopalakrishnan Unniampathu Vettical Nair, Prakash Kuttiyil Chandrasekharan Nair, Shaji Veluthalakuzhiyil Nanoo, Francis Kottackal Ouseph, Purayil Arjunan Padinhare, Sudheeran Panayamthatta, Telson Joseph Pazhampilly, Mangalan Chandrasekharan Pillai, Radhakrishna Pillai Sivarama Pillai, Sreekumar Janardhanan Pillai, Aby Molathu Poulose, Justin Poulose, Appunni Arul Prakash, Sivan Raghavan, Nibu Raju, Pradeep Chembil Raman, Sreenivasarao Raparthy, Mookaparambil Itty Raveendranathan, Vijayanair Sankarapillai, Anil Scaria, Shawkat Ali Shaikh, Arunkumar Shaw Narayan Shaw, Subash Chandra Shukla, Balwinder Singh, Mandeep Singh, Ranjit Singh, Savinder Singh, Shanmugam Subramanian, Ajith Chellayyan Swarnamma, Shibu Thankachan, Ninan John Tharakan, Jaison Antony Thekkumpuram, Kittayi Sunil Kumar Therattil, John Malakaran Thomas, Moni Panikulangara Thomas, Thenooran Kumaran Unnikrishnan, Saju Christy Vallarian, Benny Chittilappilly Vareed, George Pulikkeparambil Varghese, Kuliyanickal Paily Varghese, Shajan Varghese, Benny Kattukariyil Varkey, Thomas Varghese Vattakkattu, Isaac Wilson Vazhikudilil, Shahi Vijayan, John Yohannan. (Attachments: # 1 Memorandum in Support, # 2 Proposed Order)(Reference: 2:13−cv−06218; 2:13−cv−06219; 2:13−cv−06220; 2:13−cv−06221)(Grimsal, A.) (Entered: 02/20/2014)
190 ORDER granting 180 Motion to Appear Pro Hac Vice as to Attorney Robert M. Kline. Signed by Judge Susie Morgan on 2/20/2014. (Reference: 13cv6220)(bwn) (Entered: 02/21/2014)
191 ORDER granting 181 Motion to Appear Pro Hac Vice as to Attorney Marissa C. Krumm. Signed by Judge Susie Morgan on 2/20/2014. (Reference: 13cv6220)(bwn) (Entered: 02/21/2014)
192 TRANSCRIPT of Status Conference held on February 6, 2014 before Judge Susie Morgan. Court Reporter/Recorder Cathy Pepper, Telephone number 504−589−7779. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Recorder before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Parties have 21 days from the filing of this transcript to file with the Court a Redaction Request. Release of Transcript Restriction set for 5/22/2014. (Reference: All Cases)(rsg) (Entered: 02/21/2014)
193 ORDER granting 189 Motion for Extension of Time to Amend. IT IS ORDERED that an extension of one week to March 3, 2014, for Plaintiffs to file amended and restated Complaints in each of the consolidated cases, is GRANTED. Signed by Judge Susie Morgan. (Reference: All Cases)(bwn) (Entered: 02/21/2014)
207 Minute Entry for proceedings held before Judge Susie Morgan: Status Conference held on 2/21/2014. (Reference: All Cases)(bwn) (Entered: 03/07/2014)
194 ORDER finding as moot 188 Motion to Expedite. Signed by Judge Susie Morgan. (Reference: All Cases)(bwn) (Entered: 02/24/2014)
196 NOTICE of Change of Address by Peter Simshauser on behalf Chakkiyattil plaintiffs. (Reference: All Cases)(Simshauser, Peter) Modified docket text on 3/3/2014 (jtd). (Entered: 02/28/2014)
197 NOTICE of Change of Address by Eben P. Colby on behalf of Chakkiyattil plaintiffs. (Reference: All cases)(Colby, Eben) Modified docket text on 3/3/2014 (jtd). (Entered: 02/28/2014)
198 First AMENDED COMPLAINT with Jury Demand against Malvern C. Burnett((13−6219)), Sachin Dewan((13−6219)), Dewan Consultants Pvt.

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03/03/2014 03/03/2014
03/03/2014 03/05/2014 03/05/2014

Ltd.((13−6220)), Global Resources Inc, Gulf Coast Immigration Law Center, L.L.C.((13−6219)), Indo−Amerisoft LLC((13−6220)), Law Offices of Malvern C. Burnett, A.P.C.((13−6220)), Michael Pol, Kurella Sada Siva Rao, Signal International LLC, Signal International, Inc.((13−6221)) filed by John Malakaran Thomas, Prasad Kunju Kunju, Anil Scaria, Ampattu Varughese Mathew, Saju Christy Vallarian, Anthony Sajan Oottuparambil Michael, Benny Yohannan, Mandeep Singh, Isaac Wilson Vazhikudilil, Vijayanair Sankarapillai, Varghese Kurisinkal Devassy, George Chacko Edavazhickal.(Reference: 13−6221)(Raptis, Stephen) (Entered: 03/03/2014)
199 First AMENDED COMPLAINT with Jury Demand against All Defendants filed by Chandrasekhara Pillai Rajesh Chemmanappilly, Anthony Marian, Shajan Varghese, Sreekumar Janardhanan Pillai, Francis Kottackal Ouseph, Ajith Chellayyan Swarnamma, Sukumar Moses Dokka, Pradeep Chembil Raman, Roy Punakkattu George, Purayil Arjunan Padinhare, Arunkumar Shaw Narayan Shaw, Thomas Baby Madakkameprathu, Radhakrishnan Kakkathiruthi, Subash Chandra Shukla, Jacob Mathew, Prakash Kuttiyil Chandrasekharan Nair, Jaison Antony Thekkumpuram, Thomas Varghese Vattakkattu, John Abraham Kalampukatt, Sudheeran Panayamthatta, Shibu Thankachan, Shawkat Ali Shaikh, Davis Mathai Meledan, Shaju Olangattu Mathew, Gopalakrishnan Unniampathu Vettical Nair, Telson Joseph Pazhampilly, George Paily Paulose Chakkiyattil, Jeegan Joseph Cheruthalakal Michael. (Attachments: # 1 Exhibit A)(Reference: 13−6219)(Colby, Eben) (Entered: 03/03/2014)
200 Second AMENDED COMPLAINT with Jury Demand against Malvern C. Burnett, Sachin Dewan, Dewan Consultants Pvt. Ltd., Global Resources Inc, Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C., Michael Pol, Signal International, Inc., Signal International, LLC filed by Kulath Somanathan Kalayam, Shanmugam Subramanian, Adharsan Manuel, Ninan John Tharakan, Eldose Isac, Johny Mathew, Shaji Veluthalakuzhiyil Nanoo, Shaiju Vadakkal George, Kittayi Sunil Kumar Therattil, Savinder Singh, John Yohannan, Jacob Mazhukkattu Mathew, Joy Jacob, Praveen Kulathum Muriyi Gopalakrishnan, Biju John, Varghese Varkey Abraham, Mookaparambil Itty Raveendranathan, Parshottam Ramchandra Mangani, Sreenivasarao Raparthy, Mangalan Chandrasekharan Pillai, Justin Poulose, Xavier Disoliyan, Nandhakumar Nagaraj, Sunilkumar Marottikkal Kuttan, Shahi Vijayan, Rajankunju Geevarghese, Benny Kattukariyil Varkey, Benny Chittilappilly Vareed, Bhaskaran Sreedharan Kutty, Radhakrishna Pillai Sivarama Pillai, Nibu Raju, Aby Molathu Poulose, Kuliyanickal Paily Varghese, Appunni Arul Prakash, Shibu Joseph, Thenooran Kumaran Unnikrishnan, Lakshmanan Ponnayan Achari, Prakash Moses Kanagiah Manonmoni, Subhashithan Bahuleyan, George Pulikkeparambil Varghese, Ranjit Singh, Thansilas Joseph, Mouleswararao Guntamukkala, Kodakeril Baby Biji, Balwinder Singh, Jomon George, Moni Panikulangara Thomas.(Reference: 13cv6218)(Batchelor, Craig) (Entered: 03/03/2014)
201 First AMENDED COMPLAINT with Jury Demand against Malvern C. Burnett, Sachin Dewan, Dewan Consultants Pvt. Ltd., Global Resources Inc, Gulf Coast Immigration Law Center, L.L.C., Indo−Amerisoft LLC((13−6220)), Law Offices of Malvern C. Burnett, A.P.C., Kurella Rao, Signal International, LLC filed by Sabu Puthukkuttumel Veede Krishnakutty, Thampy Putham Parambil Edicula.(Reference: 13−6220)(Aiello, Justin) (Entered: 03/03/2014)
202 Correction of Docket Entry by Clerk re 201 Amended Complaint − Name of attorney who electronically filed this document does not match name of signatory attorney on pleading. The user log−in and password serve as the required signature for purposes of Rule 11 of the FRCP. No further action is necessary. (Reference: 13−6220)(bwn) (Entered: 03/05/2014)
203 EXPARTE/CONSENT Ex Parte MOTION to Appear Pro Hac Vice Jacob A. Walker (Filing fee $ 100 receipt number 053L−4368872) by Varghese Varkey Abraham, Lakshmanan Ponnayan Achari, Subhashithan Bahuleyan, Kodakeril Baby Biji, Xavier Disoliyan, Rajankunju Geevarghese, Jomon George, Shaiju Vadakkal George, Praveen Kulathum Muriyi Gopalakrishnan, Mouleswararao Guntamukkala, Eldose Isac, Joy Jacob, Biju John, Shibu Joseph, Thansilas Joseph, Kulath Somanathan Kalayam, Sunilkumar Marottikkal Kuttan, Bhaskaran Sreedharan Kutty, Parshottam Ramchandra Mangani, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Jacob Mazhukkattu Mathew, Johny Mathew, Nandhakumar Nagaraj, Shaji Veluthalakuzhiyil Nanoo, Mangalan Chandrasekharan Pillai, Radhakrishna Pillai Sivarama Pillai, Aby

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03/05/2014
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Molathu Poulose, Justin Poulose, Appunni Arul Prakash, Nibu Raju, Sreenivasarao Raparthy, Mookaparambil Itty Raveendranathan, Balwinder Singh, Ranjit Singh, Savinder Singh, Shanmugam Subramanian, Ninan John Tharakan, Kittayi Sunil Kumar Therattil, Moni Panikulangara Thomas, Thenooran Kumaran Unnikrishnan, Benny Chittilappilly Vareed, George Pulikkeparambil Varghese, Kuliyanickal Paily Varghese, Benny Kattukariyil Varkey, Shahi Vijayan, John Yohannan. (Attachments: # 1 Proposed Order, # 2 Exhibit 1−WalkerDeclaration, # 3 Exhibit 2−Walker Cert of Good Standing, # 4 Exhibit 3−Walker E−File Registration)(Reference: 13−6221, 13−6220, 13−6219)(Grimsal, A.) (Entered: 03/05/2014)
204 EXPARTE/CONSENT Ex Parte MOTION to Appear Pro Hac Vice Michael R. Walsh (Filing fee $ 100 receipt number 053L−4368873) by Varghese Varkey Abraham, Lakshmanan Ponnayan Achari, Subhashithan Bahuleyan, Kodakeril Baby Biji, Xavier Disoliyan, Rajankunju Geevarghese, Jomon George, Shaiju Vadakkal George, Praveen Kulathum Muriyi Gopalakrishnan, Mouleswararao Guntamukkala, Eldose Isac, Joy Jacob, Biju John, Shibu Joseph, Thansilas Joseph, Kulath Somanathan Kalayam, Sunilkumar Marottikkal Kuttan, Bhaskaran Sreedharan Kutty, Parshottam Ramchandra Mangani, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Jacob Mazhukkattu Mathew, Johny Mathew, Nandhakumar Nagaraj, Shaji Veluthalakuzhiyil Nanoo, Mangalan Chandrasekharan Pillai, Radhakrishna Pillai Sivarama Pillai, Aby Molathu Poulose, Justin Poulose, Appunni Arul Prakash, Nibu Raju, Sreenivasarao Raparthy, Mookaparambil Itty Raveendranathan, Balwinder Singh, Ranjit Singh, Savinder Singh, Shanmugam Subramanian, Ninan John Tharakan, Kittayi Sunil Kumar Therattil, Moni Panikulangara Thomas, Thenooran Kumaran Unnikrishnan, Benny Chittilappilly Vareed, George Pulikkeparambil Varghese, Kuliyanickal Paily Varghese, Benny Kattukariyil Varkey, Shahi Vijayan, John Yohannan. (Attachments: # 1 Proposed Order, # 2 Exhibit 1−Walsh Declaration, # 3 Exhibit 2−Walsh Cert of Good Standing, # 4 Exhibit 3−Walsh E−File Registration)(Reference: 13−6221, 13−6220, 13−6219)(Grimsal, A.) (Entered: 03/05/2014)
205 ORDER granting 203 Motion to Appear Pro Hac Vice as to Attorney Jacob A. Walker. Signed by Judge Susie Morgan. (Reference: All Cases)(bwn) (Entered: 03/06/2014)
206 ORDER granting 204 Motion to Appear Pro Hac Vice as to Attorney Michael R. Walsh. Signed by Judge Susie Morgan. (Reference: All Cases)(bwn) (Entered: 03/06/2014)
208 SCHEDULING ORDER: Status Conferences in all cases: 12/17/2014, 4/1/2015 and 5/1/2015. In 13−6218 Achari: Final Pretrial Conference set for 6/15/2015 02:00 PM and 1 Month Jury Trial set for 7/6/2015 09:00 AM. In 13−6219 Chakkiyattil: Final Pretrial Conference set for 12/14/2015 02:00 PM and 1 Month Jury Trial set for 1/4/2016 09:00 AM. In 13−6220 Krishnakutty: Final Pretrial Conference set for 2/8/2016 02:00 PM and 1 Month Jury Trial set for 2/29/2016 09:00 AM. In 13−6221 Devassy: Final Pretrial Conference set for 4/11/2016 02:00 PM and 1 Month Jury Trial set for 5/2/2016 09:00 AM. Signed by Judge Susie Morgan on 3/7/2014. (Attachments: # 1 Pretrial Notice Form) (Reference: All Cases) (tsf) (Entered: 03/07/2014)
209 Minute Entry for proceedings held before Judge Susie Morgan: Status Conference held on 3/10/2014. Status Conference set for 3/11/2014 01:00 PM before Judge Susie Morgan. Judge Morgan ordered the defendants in the David case and the Achari cases to file their answers to the recently filed amended complaints by March 24, 2014. (Reference: All Cases)(bwn) (Entered: 03/12/2014)
210 Minute Entry for proceedings held before Judge Susie Morgan: Status Conference held on 3/11/2014. Counsel for Signal will produce an additional 200,000 documents without review by March 17, 2014 due to the removal of these defensive search terms. Judge Morgan extended Signal's deadline to review emails and produce a privilege log to March 31, 2014.The Court directed those defendants with pending motions to dismiss to file a brief memorandum within 7 days of this order clarifying their intention to reassert their motions to dismiss with respect to the amended complaints. (Reference: All Cases)(bwn) (Entered: 03/13/2014)
211 FIRST AMENDED ORDER REGARDING PROTOCOLS FOR THE PRODUCTION OF ELECTRONICALLY STORED INFORMATION. Signed by Judge Susie Morgan on 3/12/2014.(Reference: All Cases)(bwn) (Entered: 03/13/2014)

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03/18/2014 03/18/2014 03/18/2014 03/18/2014
03/18/2014 03/19/2014 03/19/2014 03/19/2014 03/24/2014

212 EXPARTE/CONSENT MOTION to Withdraw Dominic J. Gianna and Middleberg Riddle & Gianna as Attorney of Record by Signal International, Inc., Signal International, LLC. (Attachments: # 1 Proposed Order)(Reference: 2:13−cv−06218, 2:13−cv−06219, 2:13−cv−06220, 2:13−cv−06221)(Hangartner, Erin) (Entered: 03/18/2014)
213 EXPARTE/CONSENT MOTION to Substitute Trial Attorney by Signal International, Inc., Signal International, LLC. (Attachments: # 1 Proposed Order)(Reference: 2:13−cv−06219, 2:13−cv−06220, 2:13−cv−06221)(Hangartner, Erin) (Entered: 03/18/2014)
214 Clarification of Intent to Pursue Motions to Dismiss Amended Complaints by Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C. (Reference: 13−6218, 12−6219, 13−6220, 13−6221)(Cerniglia, Timothy) (Entered: 03/18/2014)
215 RESPONSE/MEMORANDUM in Opposition filed by George Paily Paulose Chakkiyattil, Chandrasekhara Pillai Rajesh Chemmanappilly, Sukumar Moses Dokka, Roy Punakkattu George, Radhakrishnan Kakkathiruthi, John Abraham Kalampukatt, Thomas Baby Madakkameprathu, Anthony Marian, Jacob Mathew, Shaju Olangattu Mathew, Davis Mathai Meledan, Jeegan Joseph Cheruthalakal Michael, Gopalakrishnan Unniampathu Vettical Nair, Prakash Kuttiyil Chandrasekharan Nair, Francis Kottackal Ouseph, Purayil Arjunan Padinhare, Sudheeran Panayamthatta, Telson Joseph Pazhampilly, Sreekumar Janardhanan Pillai, Pradeep Chembil Raman, Shawkat Ali Shaikh, Arunkumar Shaw Narayan Shaw, Subash Chandra Shukla, Ajith Chellayyan Swarnamma, Shibu Thankachan, Jaison Antony Thekkumpuram, Shajan Varghese, Thomas Varghese Vattakkattu re 195 MOTION to Dismiss Action . (Reference: 13−6219)(Colby, Eben) (Entered: 03/18/2014)
216 Memorandum to Adopt 150 MOTION to Dismiss (Partially) Complaints for Failure to State a Claim Upon Which Relief Can Be Granted by Signal International, Inc., Signal International, LLC (Reference: 2:13−cv−06218, 2:13−cv−06219, 2:13−cv−06220, 2:13−cv−06221)(Hangartner, Erin) (Entered: 03/18/2014)
217 ORDER − The Court will conduct a telephone status conference in EEOC v. Signal (12−557), David v. Signal (08−1220), and Achari v. Signal (13−6218) (and all cases consolidated therewith) on March 24, 2014 at 3:00 p.m. Signed by Judge Susie Morgan.(Reference: All Cases)(bwn) (Entered: 03/19/2014)
218 ORDER granting 212 Motion to Withdraw as Attorney. Attorney Dominic Joseph Gianna terminated. Signed by Judge Susie Morgan. (Reference: All Cases)(bwn) (Entered: 03/19/2014)
219 ORDER granting 213 Motion to Substitute Erin Casey Hangartner as Trial Attorney in place of Hal D. Ungar. Signed by Judge Susie Morgan. (Reference: 13cv6219, 13cv6220, and 13cv6221)(bwn) (Entered: 03/19/2014)
226 Minute Entry for proceedings held before Judge Susie Morgan: Status Conference held on 3/24/2014. The Court directed counsel for plaintiffs in the David case to amend their complaint to include which law their state law claims arise under by March 31, 2014. Judge Morgan ordered counsel for Signal to file a supplemental memorandum by April 7, 2014 discussing why Signal's motion for judgment on the pleadings should be granted in light of plaintiffs' amended complaint. Plaintiffs may file a response to Signal's supplemental memorandum by April 14, 2014. The Court granted leave for the plaintiffs in the Achari cases to file a response to the memoranda filed by Signal and the Burnett defendants4 by March 31, 2014. The Court also allowed Signal to file a brief response to the plaintiffs' memoranda by April 7, 2014. Judge Morgan ordered counsel for the Dewan defendants to enroll as counsel of record in the Achari cases by March 31, 2014. Judge Morgan also ordered counsel for the Dewan defendants to file either a motion to dismiss or an answer to plaintiffs' amended complaints in the Achari cases by April 7, 2014. The Court moved the next status conference, previously scheduled for April 30, 2014, to April 29, 2014 at 1:00 p.m. Judge Morgan scheduled oral argument on Signal's Motion for Judgment on the Pleadings in the David case, and the motions to dismiss in the Achari cases filed by Signal and the Burnett defendants, for April 29, 2014 at 10:00 a.m. (Reference: All Cases)(bwn) (Entered: 04/02/2014)

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03/31/2014 03/31/2014
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04/03/2014 04/03/2014 04/07/2014

220 EXPARTE/CONSENT Ex Parte MOTION to Enroll as Counsel of Record Brian C. Roux by Signal International, Inc., Signal International, LLC. (Attachments: # 1 Proposed Order)(Reference: 2:13−cv−06218, 2:13−cv−06219, 2:13−cv−06220, 2:13−cv−06221)(Hangartner, Erin) (Entered: 03/31/2014)
221 EXPARTE/CONSENT MOTION to Withdraw Benton J. Campbell as Attorney by Varghese Varkey Abraham, Lakshmanan Ponnayan Achari, Subhashithan Bahuleyan, Kodakeril Baby Biji, Xavier Disoliyan, Rajankunju Geevarghese, Jomon George, Shaiju Vadakkal George, Praveen Kulathum Muriyi Gopalakrishnan, Mouleswararao Guntamukkala, Eldose Isac, Joy Jacob, Biju John, Shibu Joseph, Thansilas Joseph, Kulath Somanathan Kalayam, Sunilkumar Marottikkal Kuttan, Bhaskaran Sreedharan Kutty, Parshottam Ramchandra Mangani, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Jacob Mazhukkattu Mathew, Johny Mathew, Nandhakumar Nagaraj, Shaji Veluthalakuzhiyil Nanoo, Mangalan Chandrasekharan Pillai, Radhakrishna Pillai Sivarama Pillai, Aby Molathu Poulose, Justin Poulose, Appunni Arul Prakash, Nibu Raju, Sreenivasarao Raparthy, Mookaparambil Itty Raveendranathan, Balwinder Singh, Ranjit Singh, Savinder Singh, Shanmugam Subramanian, Ninan John Tharakan, Kittayi Sunil Kumar Therattil, Moni Panikulangara Thomas, Thenooran Kumaran Unnikrishnan, Benny Chittilappilly Vareed, George Pulikkeparambil Varghese, Kuliyanickal Paily Varghese, Benny Kattukariyil Varkey, Shahi Vijayan, John Yohannan. (Attachments: # 1 Proposed Order)(Reference: 2:13−cv−06218)(Grimsal, A.) (Entered: 03/31/2014)
222 RESPONSE/MEMORANDUM in Opposition filed by All Plaintiffs re 150 MOTION to Dismiss (Partially) Complaints for Failure to State a Claim Upon Which Relief Can Be Granted and 216 Memorandum to adopt. (Reference: 13−6218, 13−6219, 13−6220, 13−6221)(Raptis, Stephen) (Entered: 03/31/2014)
223 RESPONSE/MEMORANDUM in Opposition filed by All Plaintiffs re 148 MOTION to Dismiss for Failure to State a Claim (Joint Supplemental Opposition). (Attachments: # 1 Appendix A)(Reference: 13−6218; 13−6219; 13−6220; 13−6221)(Colby, Eben) (Entered: 03/31/2014)
224 ORDER granting 220 Motion to Enroll as Counsel of Record for Attorney Brian C. Roux for Signal International LLC and Signal International, Inc. Signed by Judge Susie Morgan on 4/1/2014. (Reference: All Cases)(bwn) (Entered: 04/02/2014)
225 ORDER granting 221 Motion to Withdraw as Attorney. Attorney Benton J. Campbell terminated. Signed by Judge Susie Morgan on 4/1/2014. (Reference: 13cv6218)(bwn) (Entered: 04/02/2014)
227 EXPARTE/CONSENT MOTION to Enroll as Counsel of Record by Sachin Dewan((13−6219)), Sachin Dewan, Sachin Dewan((13−6221)), Sachin Dewan((13−6220)), Dewan Consultants Pvt. Ltd.((13−6220)), Dewan Consultants Pvt. Ltd.((13−6221)), Dewan Consultants Pvt. Ltd.((13−6219)), Dewan Consultants Pvt. Ltd. (Attachments: # 1 Proposed Order)(Reference: 13−6218)Attorney Stephen H. Shapiro added to party Sachin Dewan(pty:condft), Sachin Dewan(pty:dft),Sachin Dewan(pty:condft), Sachin Dewan(pty:condft), Dewan Consultants Pvt. Ltd.(pty:condft), Dewan Consultants Pvt. Ltd.(pty:condft), Dewan Consultants Pvt. Ltd.(pty:condft), Dewan Consultants Pvt. Ltd.(pty:dft).(Shapiro, Stephen) (Entered: 04/02/2014)
228 MOTION for Judgment on the Pleadings by Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C.. Motion set for 4/29/2014 10:00 AM before Judge Susie Morgan. (Attachments: # 1 Memorandum in Support, # 2 Proposed Order, # 3 Notice of Submission)(Reference: 13−06218)(Cerniglia, Timothy) (Entered: 04/03/2014)
229 ORDER granting 227 Motion to Enroll as Counsel of Record Stephen H. Shapiro for Sachin Dewan and Dewan Consultants Pvt. Ltd.Signed by Judge Susie Morgan on 4/3/2014. (Reference: 13−6218, 13−6219, 13−6220, 13−6221)(my) (Entered: 04/04/2014)
230 ANSWER to 200 Amended Complaint with Jury Demand by Sachin Dewan((13−6219)), Sachin Dewan, Sachin Dewan((13−6221)), Sachin Dewan((13−6220)), Dewan Consultants Pvt. Ltd.((13−6220)), Dewan Consultants Pvt. Ltd.((13−6221)), Dewan Consultants Pvt. Ltd.((13−6219)), Dewan Consultants Pvt.

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04/07/2014 04/07/2014 04/07/2014 04/11/2014 04/11/2014
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04/24/2014

Ltd. (Reference: 13−6218)(Shapiro, Stephen) (Entered: 04/07/2014)
231 ANSWER to 199 Amended Complaint with Jury Demand by Sachin Dewan((13−6219)), Sachin Dewan, Sachin Dewan((13−6221)), Sachin Dewan((13−6220)), Dewan Consultants Pvt. Ltd.((13−6220)), Dewan Consultants Pvt. Ltd.((13−6221)), Dewan Consultants Pvt. Ltd.((13−6219)), Dewan Consultants Pvt. Ltd. (Reference: 13−6219)(Shapiro, Stephen) (Entered: 04/07/2014)
232 ANSWER to 201 Amended Complaint with Jury Demand by Sachin Dewan((13−6219)), Sachin Dewan, Sachin Dewan((13−6221)), Sachin Dewan((13−6220)), Dewan Consultants Pvt. Ltd.((13−6220)), Dewan Consultants Pvt. Ltd.((13−6221)), Dewan Consultants Pvt. Ltd.((13−6219)), Dewan Consultants Pvt. Ltd. (Reference: 13−6220)(Shapiro, Stephen) (Entered: 04/07/2014)
233 ANSWER to 198 Amended Complaint with Jury Demand by Sachin Dewan((13−6219)), Sachin Dewan, Sachin Dewan((13−6221)), Sachin Dewan((13−6220)), Dewan Consultants Pvt. Ltd.((13−6220)), Dewan Consultants Pvt. Ltd.((13−6221)), Dewan Consultants Pvt. Ltd.((13−6219)), Dewan Consultants Pvt. Ltd. (Reference: 13−6221)(Shapiro, Stephen) (Entered: 04/07/2014)
234 EXPARTE/CONSENT MOTION to Appear Pro Hac Vice for Ronald G. Blum (Filing fee $ 100 receipt number 053L−4415726) by Varghese Kurisinkal Devassy, George Chacko Edavazhickal, Prasad Kunju Kunju, Ampattu Varughese Mathew, Anthony Sajan Oottuparambil Michael, Sivan Raghavan, Vijayanair Sankarapillai, Anil Scaria, Mandeep Singh, John Malakaran Thomas, Saju Christy Vallarian, Isaac Wilson Vazhikudilil, Benny Yohannan. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Proposed Order)(Reference: 2:13−cv−06221)(Grimsal, A.) (Entered: 04/11/2014)
235 EXPARTE/CONSENT MOTION to Appear Pro Hac Vice for Matthew P. Kanny (Filing fee $ 100 receipt number 053L−4415767) by Varghese Kurisinkal Devassy, George Chacko Edavazhickal, Prasad Kunju Kunju, Ampattu Varughese Mathew, Anthony Sajan Oottuparambil Michael, Sivan Raghavan, Vijayanair Sankarapillai, Anil Scaria, Mandeep Singh, John Malakaran Thomas, Saju Christy Vallarian, Isaac Wilson Vazhikudilil, Benny Yohannan. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Proposed Order)(Reference: 2:13−cv−06221)(Grimsal, A.) (Entered: 04/11/2014)
236 ORDER granting 234 Motion to Appear Pro Hac Vice as to Ronald G. Blum. Signed by Judge Susie Morgan. (Reference: 13−6221)(bwn) (Entered: 04/14/2014)
237 ORDER granting 235 Motion to Appear Pro Hac Vice as to Matthew P. Kanny.. Signed by Judge Susie Morgan. (Reference: 13−6221)(bwn) (Entered: 04/14/2014)
238 RESPONSE/MEMORANDUM in Opposition filed by Varghese Varkey Abraham, Lakshmanan Ponnayan Achari, Subhashithan Bahuleyan, Kodakeril Baby Biji, Xavier Disoliyan, Rajankunju Geevarghese, Jomon George, Shaiju Vadakkal George, Praveen Kulathum Muriyi Gopalakrishnan, Mouleswararao Guntamukkala, Eldose Isac, Joy Jacob, Biju John, Shibu Joseph, Thansilas Joseph, Kulath Somanathan Kalayam, Sunilkumar Marottikkal Kuttan, Bhaskaran Sreedharan Kutty, Parshottam Ramchandra Mangani, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Jacob Mazhukkattu Mathew, Johny Mathew, Nandhakumar Nagaraj, Shaji Veluthalakuzhiyil Nanoo, Mangalan Chandrasekharan Pillai, Radhakrishna Pillai Sivarama Pillai, Aby Molathu Poulose, Justin Poulose, Appunni Arul Prakash, Nibu Raju, Sreenivasarao Raparthy, Mookaparambil Itty Raveendranathan, Balwinder Singh, Ranjit Singh, Savinder Singh, Shanmugam Subramanian, Ninan John Tharakan, Kittayi Sunil Kumar Therattil, Moni Panikulangara Thomas, Thenooran Kumaran Unnikrishnan, Benny Chittilappilly Vareed, George Pulikkeparambil Varghese, Kuliyanickal Paily Varghese, Benny Kattukariyil Varkey, Shahi Vijayan, John Yohannan re 228 MOTION for Judgment on the Pleadings (Reference: 13−6218)(Adams, Daniel) (Entered: 04/21/2014)
239 ORDER − Oral argument will be held on April 29, 2014 at 10:00 a.m. on the following motions: 148 MOTION to Dismiss for Failure to State a Claim , 150 MOTION to Dismiss (Partially) Complaints for Failure to State a Claim Upon Which Relief Can Be Granted, 228 MOTION for Judgment on the Pleadings . Hearing schedule detailed herein. Signed by Judge Susie Morgan on 4/23/2014.(Reference: All Cases)(bwn) (Entered: 04/24/2014)

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04/24/2014
04/29/2014
05/08/2014 05/08/2014
05/09/2014 05/09/2014 05/14/2014 05/15/2014 05/16/2014 05/16/2014

240 ORDER − IT IS ORDERED that the Singh case and the Achari cases be and hereby are CONSOLIDATED. All subsequent pleadings relating to any of these cases shall bear the caption as set forth within. The document should include a separate notation listing the docket numbers to which the document applies or the notation ALL CASES if it applies to all cases. The parties in the Singh case shall comply with the Scheduling Order entered on March 7, 2014 in the Achari cases applicable to all of the consolidated cases with the exception of the following deadlines applicable only to the Singh case: scheduling details noted herein. Signed by Judge Susie Morgan on 4/23/2014.(Reference: 14−732)(bwn) (Entered: 04/24/2014)
245 Minute Entry for proceedings held before Judge Susie Morgan: Status Conference held on 4/29/2014. The Court ordered counsel for Signal to send the Rule 30(b)(6) deposition notices in the EEOC case, the David case, and the Achari cases to counsel for plaintiffs in the Texas cases. The Court ordered the depositions of Signal employees to begin on Mondays and instructed counsel for all parties to inform deponents that they must be available the entire week. The Court extended the deadline for the depositions of Signal's employees to July 11, 2014. The Court directed counsel for Signal to distribute an updated chart by May 5, 2014 outlining its Rule (30)(b)(6) designees, the topics on which the witnesses will testify, and the dates on which the depositions will occur. The Court ordered counsel for all parties to meet and confer regarding Signal's proposed schedule. (Reference: All Cases)(bwn) (Entered: 05/13/2014)
241 EXPARTE/CONSENT MOTION to Appear Pro Hac Vice for Ryan J. Alshak (Filing fee $ 100 receipt number 053L−4444544) by Varghese Kurisinkal Devassy, George Chacko Edavazhickal, Prasad Kunju Kunju, Ampattu Varughese Mathew, Anthony Sajan Oottuparambil Michael, Sivan Raghavan, Vijayanair Sankarapillai, Anil Scaria, Mandeep Singh, John Malakaran Thomas, Saju Christy Vallarian, Isaac Wilson Vazhikudilil, Benny Yohannan. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Proposed Order)(Reference: 2:13−cv−06221)(Grimsal, A.) (Entered: 05/08/2014)
242 EXPARTE/CONSENT MOTION to Appear Pro Hac Vice for Christopher A. Rheinheimer (Filing fee $ 100 receipt number 053L−4444597) by Varghese Kurisinkal Devassy, George Chacko Edavazhickal, Prasad Kunju Kunju, Ampattu Varughese Mathew, Anthony Sajan Oottuparambil Michael, Sivan Raghavan, Vijayanair Sankarapillai, Anil Scaria, Mandeep Singh, John Malakaran Thomas, Saju Christy Vallarian, Isaac Wilson Vazhikudilil, Benny Yohannan. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Proposed Order)(Reference: 2:13−cv−06221)(Grimsal, A.) (Entered: 05/08/2014)
243 ORDER granting 241 Motion to Appear Pro Hac Vice as to Attorney Ryan J. Alshak. Signed by Judge Susie Morgan on 5/9/2014. (Reference: 13−6221)(bwn) (Entered: 05/12/2014)
244 ORDER granting 242 Motion to Appear Pro Hac Vice as to Attorney Christopher A. Rheinheimer. Signed by Judge Susie Morgan on 5/9/2014. (Reference: 13−6221)(bwn) (Entered: 05/12/2014)
246 EXPARTE/CONSENT MOTION to Appear Pro Hac Vice for Danielle E. Johnson (Filing fee $ 100 receipt number 053L−4450686) by Pravin Kumar Singh, Radhakrishnan Nair Mangalathu Vasukuttan. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Proposed Order)(Reference: 14−732)(Grimsal, A.) (Entered: 05/14/2014)
247 EXPARTE/CONSENT MOTION to Appear Pro Hac Vice for Mona Mehta (Filing fee $ 100 receipt number 053L−4452811) by Pravin Kumar Singh, Radhakrishnan Nair Mangalathu Vasukuttan. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Proposed Order)(Reference: 14−732)(Grimsal, A.) (Entered: 05/15/2014)
248 Witness List by Signal International, Inc., Signal International, LLC. (Reference: 2:13−cv−06218, 2:13−cv−06219, 2:13−cv−06220, 2:13−cv−06221, 14−732)(Hangartner, Erin) (Entered: 05/16/2014)
249 EXPARTE/CONSENT MOTION to Appear Pro Hac Vice for Katelyn M. Beaudette (Filing fee $ 100 receipt number 053L−4454375) by Varghese Varkey Abraham, Lakshmanan Ponnayan Achari, Subhashithan Bahuleyan, Kodakeril Baby Biji, Xavier Disoliyan, Rajankunju Geevarghese, Jomon George, Shaiju Vadakkal George, Praveen

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05/16/2014
05/16/2014
05/20/2014 05/20/2014

Kulathum Muriyi Gopalakrishnan, Mouleswararao Guntamukkala, Eldose Isac, Joy Jacob, Biju John, Shibu Joseph, Thansilas Joseph, Kulath Somanathan Kalayam, Sunilkumar Marottikkal Kuttan, Bhaskaran Sreedharan Kutty, Parshottam Ramchandra Mangani, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Jacob Mazhukkattu Mathew, Johny Mathew, Nandhakumar Nagaraj, Shaji Veluthalakuzhiyil Nanoo, Mangalan Chandrasekharan Pillai, Radhakrishna Pillai Sivarama Pillai, Aby Molathu Poulose, Justin Poulose, Appunni Arul Prakash, Nibu Raju, Sreenivasarao Raparthy, Mookaparambil Itty Raveendranathan, Balwinder Singh, Ranjit Singh, Savinder Singh, Shanmugam Subramanian, Ninan John Tharakan, Kittayi Sunil Kumar Therattil, Moni Panikulangara Thomas, Thenooran Kumaran Unnikrishnan, Benny Chittilappilly Vareed, George Pulikkeparambil Varghese, Kuliyanickal Paily Varghese, Benny Kattukariyil Varkey, Shahi Vijayan, John Yohannan. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Proposed Order)(Reference: 13−6218)(Grimsal, A.) (Entered: 05/16/2014)
250 EXPARTE/CONSENT MOTION to Appear Pro Hac Vice for Matthew Salerno (Filing fee $ 100 receipt number 053L−4454376) by Varghese Varkey Abraham, Lakshmanan Ponnayan Achari, Subhashithan Bahuleyan, Kodakeril Baby Biji, Xavier Disoliyan, Rajankunju Geevarghese, Jomon George, Shaiju Vadakkal George, Praveen Kulathum Muriyi Gopalakrishnan, Mouleswararao Guntamukkala, Eldose Isac, Joy Jacob, Biju John, Shibu Joseph, Thansilas Joseph, Kulath Somanathan Kalayam, Sunilkumar Marottikkal Kuttan, Bhaskaran Sreedharan Kutty, Parshottam Ramchandra Mangani, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Jacob Mazhukkattu Mathew, Johny Mathew, Nandhakumar Nagaraj, Shaji Veluthalakuzhiyil Nanoo, Mangalan Chandrasekharan Pillai, Radhakrishna Pillai Sivarama Pillai, Aby Molathu Poulose, Justin Poulose, Appunni Arul Prakash, Nibu Raju, Sreenivasarao Raparthy, Mookaparambil Itty Raveendranathan, Balwinder Singh, Ranjit Singh, Savinder Singh, Shanmugam Subramanian, Ninan John Tharakan, Kittayi Sunil Kumar Therattil, Moni Panikulangara Thomas, Thenooran Kumaran Unnikrishnan, Benny Chittilappilly Vareed, George Pulikkeparambil Varghese, Kuliyanickal Paily Varghese, Benny Kattukariyil Varkey, Shahi Vijayan, John Yohannan. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Proposed Order)(Reference: 13−6218)(Grimsal, A.) (Entered: 05/16/2014)
251 EXPARTE/CONSENT MOTION to Appear Pro Hac Vice for Grant F. Wahlquist (Filing fee $ 100 receipt number 053L−4454377) by Varghese Varkey Abraham, Lakshmanan Ponnayan Achari, Subhashithan Bahuleyan, Kodakeril Baby Biji, Xavier Disoliyan, Rajankunju Geevarghese, Jomon George, Shaiju Vadakkal George, Praveen Kulathum Muriyi Gopalakrishnan, Mouleswararao Guntamukkala, Eldose Isac, Joy Jacob, Biju John, Shibu Joseph, Thansilas Joseph, Kulath Somanathan Kalayam, Sunilkumar Marottikkal Kuttan, Bhaskaran Sreedharan Kutty, Parshottam Ramchandra Mangani, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Jacob Mazhukkattu Mathew, Johny Mathew, Nandhakumar Nagaraj, Shaji Veluthalakuzhiyil Nanoo, Mangalan Chandrasekharan Pillai, Radhakrishna Pillai Sivarama Pillai, Aby Molathu Poulose, Justin Poulose, Appunni Arul Prakash, Nibu Raju, Sreenivasarao Raparthy, Mookaparambil Itty Raveendranathan, Balwinder Singh, Ranjit Singh, Savinder Singh, Shanmugam Subramanian, Ninan John Tharakan, Kittayi Sunil Kumar Therattil, Moni Panikulangara Thomas, Thenooran Kumaran Unnikrishnan, Benny Chittilappilly Vareed, George Pulikkeparambil Varghese, Kuliyanickal Paily Varghese, Benny Kattukariyil Varkey, Shahi Vijayan, John Yohannan. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Proposed Order)(Reference: 13−6218)(Grimsal, A.) (Entered: 05/16/2014)
252 ORDER − The Court will conduct a telephone status conference in EEOC v. Signal (12−557), David v. Signal (08−1220), and Achari v. Signal (13−6218) (and all cases consolidated therewith) on May 21, 2014 at 11:00 a.m. The Court will provide the parties with the call−in instructions necessary to participate in the conference via telephone. Signed by Judge Susie Morgan.(Reference: All Cases)(bwn) (Entered: 05/20/2014)
253 ORDER granting 246 Motion to Appear Pro Hac Vice as to Danielle E. Johnson. Signed by Judge Susie Morgan on 5/19/2014. (Reference: 14−732)(bwn) (Entered: 05/20/2014)

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254 ORDER granting 247 Motion to Appear Pro Hac Vice as to Mona Mehta. Signed by Judge Susie Morgan on 5/19/2014. (Reference: 14−732)(bwn) (Entered: 05/20/2014)
255 ORDER granting 249 Motion to Appear Pro Hac Vice as to Katelyn M. Beaudette. Signed by Judge Susie Morgan on 5/19/2014. (Reference: 13−6218)(bwn) (bwn). (Entered: 05/20/2014)
256 ORDER granting 250 Motion to Appear Pro Hac Vice as to Matthew S. Salerno.. Signed by Judge Susie Morgan on 5/19/2014. (Reference: 13−6218)(bwn) (Entered: 05/20/2014)
257 ORDER granting 251 Motion to Appear Pro Hac Vice as to Grant F. Wahlquist.. Signed by Judge Susie Morgan on 5/19/2014. (Reference: 13−6218)(bwn) (Entered: 05/20/2014)
258 Motion to Transfer For Coordinated or Consolidated Pretrial Proceedings re MDL 2554 by Signal International, Inc. (Attachments: # 1 Brief in Support, # 2 Exhibit List, # 3 Schedule of Actions, # 4 Corporate Disclosure Statement, # 5 Correspondence, # 6 Proof of Service)(Reference: All Cases)(bwn) (Entered: 05/21/2014)
259 EXPARTE/CONSENT MOTION to Appear Pro Hac Vice for Sarah Chandrika (Filing fee $ 100 receipt number 053L−4459115) by Varghese Varkey Abraham, Lakshmanan Ponnayan Achari, Subhashithan Bahuleyan, Kodakeril Baby Biji, Xavier Disoliyan, Rajankunju Geevarghese, Jomon George, Shaiju Vadakkal George, Praveen Kulathum Muriyi Gopalakrishnan, Mouleswararao Guntamukkala, Eldose Isac, Joy Jacob, Biju John, Shibu Joseph, Thansilas Joseph, Kulath Somanathan Kalayam, Sunilkumar Marottikkal Kuttan, Bhaskaran Sreedharan Kutty, Parshottam Ramchandra Mangani, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Jacob Mazhukkattu Mathew, Johny Mathew, Nandhakumar Nagaraj, Shaji Veluthalakuzhiyil Nanoo, Mangalan Chandrasekharan Pillai, Radhakrishna Pillai Sivarama Pillai, Aby Molathu Poulose, Justin Poulose, Appunni Arul Prakash, Nibu Raju, Sreenivasarao Raparthy, Mookaparambil Itty Raveendranathan, Balwinder Singh, Ranjit Singh, Savinder Singh, Shanmugam Subramanian, Ninan John Tharakan, Kittayi Sunil Kumar Therattil, Moni Panikulangara Thomas, Thenooran Kumaran Unnikrishnan, Benny Chittilappilly Vareed, George Pulikkeparambil Varghese, Kuliyanickal Paily Varghese, Benny Kattukariyil Varkey, Shahi Vijayan, John Yohannan. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Proposed Order)(Reference: 13−6218)(Grimsal, A.) (Entered: 05/21/2014)
264 Minute Entry for proceedings held before Judge Susie Morgan: Telephone Conference held on 5/21/2014. (Reference: All Cases)(bwn) (Entered: 05/27/2014)
260 ORDER granting 259 Motion to Appear Pro Hac Vice as to Sarah C. Chandrika. Signed by Judge Susie Morgan. (Reference: 13−6218)(bwn) (Entered: 05/23/2014)
261 EXPARTE/CONSENT MOTION to Appear Pro Hac Vice for Mostafa M. Abdelkarim (Filing fee $ 100 receipt number 053L−4462235) by Pravin Kumar Singh, Radhakrishnan Nair Mangalathu Vasukuttan. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Proposed Order)(Reference: 14−00732)(Grimsal, A.) (Entered: 05/23/2014)
262 EXPARTE/CONSENT MOTION for Extension of Time to Answer Singh Plaintiff's Complaint by Sachin Dewan((13−6220)), Dewan Consultants Pvt. Ltd.((13−6219)). (Attachments: # 1 Memorandum in Support, # 2 Proposed Order, # 3 Proposed Pleading)(Reference: 14−732)(Shapiro, Stephen) (Entered: 05/23/2014)
263 EXPARTE/CONSENT MOTION for Leave to File Corrected Memorandum in Support re 262 Motion for Leave to File Answer to Singh Plaintiff's Complaint by Sachin Dewan((13−6220)), Dewan Consultants Pvt. Ltd.((13−6219)). (Attachments: # 1 Proposed Pleading, # 2 Proposed Order)(Reference: 14−472)(Shapiro, Stephen) (Entered: 05/27/2014)
265 ORDER granting 261 Motion to Appear Pro Hac Vice as to Mostafa M. Abdelkarim.. Signed by Judge Susie Morgan. (Reference: 14−732)(bwn) (Entered: 05/27/2014)
266 EXPARTE/CONSENT MOTION to Appear Pro Hac Vice for Joshua Asher (Filing fee $ 100 receipt number 053L−4465410) by Pravin Kumar Singh, Radhakrishnan Nair Mangalathu Vasukuttan. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4

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05/28/2014 05/28/2014 05/29/2014 05/29/2014 06/02/2014
06/06/2014
06/09/2014 06/10/2014 06/11/2014 06/12/2014 06/13/2014 06/18/2014
06/23/2014 06/25/2014 07/01/2014

Proposed Order)(Reference: 14−00732)(Grimsal, A.) (Entered: 05/28/2014)
267 ORDER granting 262 Motion for Extension of Time to Answer Singh Plaintiff's Complaint. Signed by Judge Susie Morgan on 5/28/2014. (Reference: 14−732)(bwn) (Entered: 05/29/2014)
268 ANSWER to Singh Complaint by Sachin Dewan((14−732)), Dewan Consultants Pvt. Ltd.((14−732)).(Reference: 14−732)(bwn) (Entered: 05/29/2014)
269 ORDER finding as moot 263 Motion for Leave to File Corrected Memorandum in Support re 262 Motion for Leave to File Answer to Singh Plaintiff's Complaint. Signed by Judge Susie Morgan on 5/28/2014. (Reference: 14−732)(bwn) (Entered: 05/29/2014)
270 ORDER granting 266 Motion to Appear Pro Hac Vice as to Joshua D. Asher. Signed by Judge Susie Morgan on 5/29/2014. (Reference: 14−732)(bwn) (Entered: 05/30/2014)
271 ORDER clarifying Court's previous order relating to depositions taken in David v. Signal (08−1220) (the "David case"), EEOC v. Signal (12−557) (the "EEOC case"), and Achari v. Signal (13−6218, c/w 13−6219, 13−6220, 13−6221, 14−732) (the "Achari cases"). Signed by Judge Susie Morgan.(Reference: All Cases)(bwn) (Entered: 06/02/2014)
272 EXPARTE/CONSENT MOTION to Appear Pro Hac Vice for Eric B. Chen (Filing fee $ 100 receipt number 053L−4477234) by Varghese Kurisinkal Devassy, George Chacko Edavazhickal, Prasad Kunju Kunju, Ampattu Varughese Mathew, Anthony Sajan Oottuparambil Michael, Sivan Raghavan, Vijayanair Sankarapillai, Anil Scaria, Mandeep Singh, John Malakaran Thomas, Saju Christy Vallarian, Isaac Wilson Vazhikudilil, Benny Yohannan. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Proposed Order)(Reference: 13−6221)(Grimsal, A.) (Entered: 06/06/2014)
273 ORDER granting 272 Motion to Appear Pro Hac Vice as to Eric B. Chen. Signed by Judge Susie Morgan on 6/9/2014. (Reference: 13−6221)(bwn) (Entered: 06/10/2014)
274 EXPARTE/CONSENT MOTION to Appear Pro Hac Vice Ashley M. Sprague (Filing fee $ 100 receipt number 053L−4480233) by Pravin Kumar Singh, Radhakrishnan Nair Mangalathu Vasukuttan. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Proposed Order)(Reference: 14−732)(Grimsal, A.) (Entered: 06/10/2014)
275 ORDER granting 274 Motion to Appear Pro Hac Vice as to Ashley M. Sprague. Signed by Judge Susie Morgan. (Reference: 14−732)(bwn) (Entered: 06/11/2014)
276 EXPARTE/CONSENT MOTION to Appear Pro Hac Vice for Jessica D. Rostoker (Filing fee $ 100 receipt number 053L−4483560) by Achari Plaintiffs. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Proposed Order)(Reference: 13−6218)(Grimsal, A.) (Entered: 06/12/2014)
277 ORDER granting 276 Motion to Appear Pro Hac Vice as to Jessica D. Rostoker. Signed by Judge Susie Morgan on 6/13/2014. (Reference: 13−6218)(bwn) (Entered: 06/16/2014)
278 ORDER − IT IS ORDERED that the Motion to Withdraw as Counsel of Record for the Dewan Defendants is hereby set for hearing/submission on the 2nd day of July, 2014 at 2:00 p.m. The David plaintiffs opposition memorandum shall be filed on the 24th day of June, 2014. Signed by Judge Susie Morgan.(Reference: All Cases)(bwn) (Entered: 06/18/2014)
279 ORDER − Telephone Status Conference set for 6/25/2014 11:00 AM before Judge Susie Morgan. Signed by Judge Susie Morgan.(Reference: All Cases)(bwn) (Entered: 06/23/2014)
280 Minute Entry for proceedings held before Judge Susie Morgan: Status Conference held on 6/25/2014. Status Conference set for 7/28/2014 04:00 PM before Judge Susie Morgan. (Reference: ALL CASES)(caa) (Entered: 06/30/2014)
281 EXPARTE/CONSENT MOTION to Enroll as Counsel of Record Lance R. Rydberg by Signal International, Inc., Signal International, LLC. (Attachments: # 1 Proposed Order)(Reference: 13−6218, 13−6219, 13−6220, 13−6221 & 14−732)(Hangartner,

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07/02/2014 07/07/2014 07/08/2014
07/08/2014 07/09/2014
07/11/2014 07/11/2014 07/11/2014 07/28/2014
07/28/2014 07/30/2014 07/30/2014 08/01/2014
08/01/2014

Erin) (Entered: 07/01/2014)
282 ORDER granting 281 Motion to Enroll Attorney Lance R. Rydberg as Additional Counsel of Record for Signal International LLC. (Reference: All Cases)(bwn) (Entered: 07/02/2014)
283 Minute Entry for proceedings held before Judge Susie Morgan: Telephone Status Conference held on 7/7/2014. (Reference: All Cases)(bwn) (Entered: 07/08/2014)
284 ORDER re Deadlines for Expert Reports. In the David case, plaintiffs' reports in the Global Categories are due on August 20, 2014. In the Achari case and the Chakkiyattil case, plaintiffs' reports in the Global Categories are due on December 31, 2014. These reports must be provided by August 20, 2014 in the David case and by December 31, 2014 in the Achari case and the Chakkiyattil case. Signed by Judge Susie Morgan on 7/8/2014.(Reference: All Cases)(bwn) (Entered: 07/09/2014)
285 ORDER − Upon request by counsel, the Court extended the deadline for oppositions to the Dewan Defendants' motion for protective order to July 9, 2014 at 5:00 p.m. Signed by Judge Susie Morgan on 7/8/2014.(Reference: All Cases)(bwn) (Entered: 07/09/2014)
286 MOTION to Bifurcate Trial Relative to Attorney's Fees by Signal International, Inc., Signal International, LLC. Motion set for 7/30/2014 10:00 AM before Judge Susie Morgan. (Attachments: # 1 Memorandum in Support, # 2 Notice of Submission, # 3 Exhibit 1, # 4 Exhibit 2, # 5 Exhibit 3, # 6 Exhibit 4)(Reference: 13−6218, 13−6219, 13−6220, 13−6221 & 14−732)(Hangartner, Erin) (Entered: 07/09/2014)
287 Reply to the Oppositions to Motion for Protective Order by Sachin Dewan, Dewan Consultants Pvt. Ltd. (Reference: All Cases)(bwn) (Entered: 07/11/2014)
288 ORDER AND REASONS − IT IS ORDERED that Dewan's Motion for Protective Order be and hereby is GRANTED IN PART as set forth herein and otherwise DENIED. Signed by Judge Susie Morgan.(Reference: All Cases)(bwn) (Entered: 07/11/2014)
289 ORDER AND REASONS − IT IS ORDERED that Burnett's Motion for Protective Order be and hereby is GRANTED IN PART as set forth herein. Signed by Judge Susie Morgan. (Reference: All Cases)(bwn) (Entered: 07/11/2014)
290 EXPARTE/CONSENT MOTION for Leave to File Reply Memorandum of Signal Further Supporting Motion to Bifurcate Trial Relative to Attorney's Fees by Signal International, Inc., Signal International, LLC. (Attachments: # 1 Proposed Order, # 2 Proposed Pleading)(Reference: 13−6218, 13−6219, 13−6220, 13−6221 & 14−732)(Hangartner, Erin) (Entered: 07/28/2014)
303 Minute Entry for proceedings held before Judge Susie Morgan: Status Conference held on 7/28/2014. Signals 286 motion to bifurcate filed in the David case, the EEOC case, and the Achari cases be and here by is DENIED as moot. (Reference: All Cases)(bwn) (Entered: 08/13/2014)
291 ORDER granting 290 Motion for Leave to File Reply Memorandum of Signal Further Supporting Motion to Bifurcate Trial Relative to Attorney's Fees. Signed by Judge Susie Morgan. (Reference: All Cases)(bwn) (Entered: 07/30/2014)
292 Reply Memorandum by Signal International, Inc. to 286 MOTION to Bifurcate Trial Relative to Attorney's Fees (Reference: All Cases)(bwn) (Entered: 07/30/2014)
293 MOTION for Leave to File Supplemental Fact Witness List by Signal International, Inc., Signal International, LLC. Motion set for 8/27/2014 10:00 AM before Judge Susie Morgan. (Attachments: # 1 Memorandum in Support, # 2 Exhibit A, # 3 Proposed Pleading, # 4 Notice of Submission, # 5 Proposed Order)(Reference: 13−6218, 13−6219, 13−6220, 13−6221 & 14−732)(Hangartner, Erin) (Entered: 08/01/2014)
294 EXPARTE/CONSENT MOTION to Expedite Signal's Motion for Leave to File Supplemental Fact Witness List by Signal International, Inc., Signal International, LLC. (Attachments: # 1 Memorandum in Support, # 2 Notice of Submission, # 3 Proposed Order)(Reference: 13−6218, 13−6219, 13−6220, 13−6221 &

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08/04/2014 08/04/2014 08/04/2014
08/05/2014 08/08/2014
08/12/2014
08/12/2014 08/12/2014
08/12/2014 08/13/2014 08/14/2014 08/18/2014

14−732)(Hangartner, Erin) Modified on 8/1/2014 to remove submission info (bwn). (Entered: 08/01/2014)
295 EXPARTE/CONSENT Consent MOTION for Leave to File Reply Memorandum of Signal to Opposition of Plaintiffs to Motion for Leave to Supplement Fact Witness List by Signal International, Inc., Signal International, LLC. (Attachments: # 1 Proposed Order, # 2 Proposed Pleading)(Reference: 13−6218, 13−6219, 13−6220, 13−6221 & 14−732)(Hangartner, Erin) (Entered: 08/04/2014)
296 ORDER granting 294 Motion to Expedite. Signed by Judge Susie Morgan. (Reference: All Cases)(bwn) (Entered: 08/04/2014)
297 ORDER denying 293 Motion for Leave to Supplement the Fact Witness List in the David case, as stated herein. FURTHER ORDER denying as moot 293 Motion for Leave to Supplement Fact Witness List in the EEOC and Achari cases, as stated herein. FURTHER ORDER quashing 293 Motion to Notice Depositions for August 5 and 6, 2014, as further stated herein. Signed by Judge Susie Morgan on 8/4/2014. (Reference: All Cases) (tsf) (Entered: 08/04/2014)
298 ORDER finding as moot 295 Motion for Leave to File Reply Memorandum of Signal to Opposition to Plaintiffs to Motion for Leave to Supplement Fact Witness List. Signed by Judge Susie Morgan. (Reference: All Cases)(bwn) (Entered: 08/05/2014)
299 MOTION to Quash Signal's Bank Records Subpoenas by Lakshmanan Ponnayan Achari, George Paily Paulose Chakkiyattil, Varghese Kurisinkal Devassy, Sabu Puthukkuttumel Veede Krishnakutty, Pravin Kumar Singh. Motion referred to Magistrate Judge Daniel E. Knowles, III. Motion set for 8/27/2014 11:00 AM before Magistrate Judge Daniel E. Knowles, III. (Attachments: # 1 Memorandum in Support, # 2 Exhibit 1, # 3 Notice of Submission)(Reference: 13−6218, 13−6219, 13−6220, 13−6221, 14−732)(Colby, Eben) Modified hearing info on 8/12/2014 (plh). (Entered: 08/08/2014)
300 Correction of Docket Entry by Clerk re 299 MOTION to Quash Signal's Bank Records Subpoenas; **Filing attorney should have changed 'N' to 'Y' at the question 'Is this motion to be decided by the Magistrate Judge Y/N?'. This motion will be decided by the magistrate judge. Motion set for 8/27/2014 11:00 AM before Magistrate Judge Daniel E. Knowles, III. Clerk took corrective action.** (Reference: All Cases)(plh) (Entered: 08/12/2014)
301 ORDER Setting ORAL Hearing on 299 MOTION to Quash Signal's Bank Records Subpoenas : Motion set for ORAL HEARING 8/27/2014 11:00 AM before Magistrate Judge Daniel E. Knowles III. Signed by Magistrate Judge Daniel E. Knowles, III on 8/12/14.(Reference: All Cases)(plh) (Entered: 08/12/2014)
302 ORDER − IT IS ORDERED that the parties in the David case and the Achari cases shall file cross−motions for partial summary judgment on the choice of law issue for Plaintiffs' state law claims. With respect to the Achari cases, the parties' briefs shall include a discussion of whether or not the ruling in Ferens v. John Deere Co. applies. 494 U.S. 516 (1990). The parties shall file their cross motions no later than September 9, 2014. Oppositions to the cross motions shall be filed no later than September 23, 2014. Signed by Judge Susie Morgan on 8/12/2014.(Reference: All Cases)(bwn) (Entered: 08/13/2014)
304 ORDER Denying MDL Transfer and Consolidation. Signed by MDL Panel.(Reference: All Cases)(bwn) (Entered: 08/13/2014)
305 ORDER AND REASONS denying 148 Motion to Dismiss for Failure to State a Claim; denying 150 Motion to Dismiss; denying 228 Motion for Judgment on the Pleadings. Signed by Judge Susie Morgan. (Reference: 13−6218; 13−6218; 13−6220; and 13−6221)(bwn) (Entered: 08/13/2014)
306 ORDER AND REASONS denying 195 Motion to Dismiss. Signed by Judge Susie Morgan. (Reference: 13−6218; 13−6219; 13−6200; 13−6221)(bwn) (Entered: 08/14/2014)
307 ORDER AND REASONS granting 144 Motion for Protective Order, as stated herein. FURTHER ORDER that the Plaintiffs in the Achari cases are to produce affidavits attached to their T or U visa applications to Defendants within 30 days of the date of

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08/18/2014
08/19/2014 08/19/2014 08/19/2014 08/20/2014
08/21/2014 08/22/2014
08/24/2014 08/25/2014 08/25/2014

this order, as further stated herein. Signed by Judge Susie Morgan on 8/18/2014. (Reference: All Cases) (tsf) (Entered: 08/18/2014)
308 MOTION to Withdraw Stephen H. Shapiro as Attorney by Sachin Dewan((13−6219)), Sachin Dewan((14−732)), Sachin Dewan, Sachin Dewan((13−6221)), Sachin Dewan((13−6220)), Dewan Consultants Pvt. Ltd.((13−6220)), Dewan Consultants Pvt. Ltd.((13−6221)), Dewan Consultants Pvt. Ltd.((14−732)), Dewan Consultants Pvt. Ltd.((13−6219)), Dewan Consultants Pvt. Ltd..Motion set for 9/10/2014 10:00 AM before Judge Susie Morgan. (Attachments: # 1 Memorandum in Support, # 2 Notice of Submission, # 3 Proposed Order)(Reference: 13−6218, 13−6219, 13−6220, 13−6221, 14−472)Attorney Stephen H. Shapiro added to party Sachin Dewan(pty:condft), Attorney Stephen H. Shapiro added to party Dewan Consultants Pvt. Ltd.(pty:condft).(Shapiro, Stephen) Modified on 8/19/2014 (cms). (Entered: 08/18/2014)
309 Correction of Docket Entry by Clerk re 308 MOTION to Withdraw Stephen H. Shapiro as Attorney ; Filing attorney incorrectly changed 'N' to 'Y' at the question 'Is this motion to be decided by the Magistrate Judge Y/N?'. This motion will be decided by the district judge. Clerk took corrective action. (Reference: 13−6218,13−6219,13−6220,13−6221,14−472)(cms) (Entered: 08/19/2014)
310 EXPARTE/CONSENT MOTION for Extension of Deadlines to Exchange Fact Witness and Exhibit Lists by Lakshmanan Ponnayan Achari, George Paily Paulose Chakkiyattil, Varghese Kurisinkal Devassy, Sabu Puthukkuttumel Veede Krishnakutty, Pravin Kumar Singh. (Attachments: # 1 Proposed Order)(Reference: 13−6218, 13−6219, 13−6220, 13−6221, 14−732)(Arvelo, Jose) (Entered: 08/19/2014)
311 RESPONSE/MEMORANDUM in Opposition filed by Signal International, Inc., Signal International, LLC re 299 MOTION to Quash Signal's Bank Records Subpoenas Issued to M & M Bank. (Reference: 13−6218, 13−6219, 13−6220, 13−6221, 14−732)(Hangartner, Erin) (Entered: 08/19/2014)
312 TRANSCRIPT of Status Conference held on July 28, 2014 before Judge Susie Morgan. Court Reporter/Recorder Cathy Pepper, Telephone number 504−589−7779. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Recorder before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Parties have 21 days from the filing of this transcript to file with the Court a Redaction Request. (Related to 08−1220, 12−557; applies to all cases) Release of Transcript Restriction set for 11/18/2014. (Reference: All Cases)(rsg) (Entered: 08/20/2014)
313 ORDER denying 310 Motion for Extension of Deadlines. Signed by Judge Susie Morgan on 8/20/2014. (Reference: 13−6218, 13−6219, 13−6220, 13−6221, 14−732)(my) (Entered: 08/21/2014)
314 EXPARTE/CONSENT MOTION for Leave to File Reply Memorandum In Further Support Of Their Motion To Quash Signal's Bank Records Subpoenas by Lakshmanan Ponnayan Achari, George Paily Paulose Chakkiyattil, Varghese Kurisinkal Devassy, Sabu Puthukkuttumel Veede Krishnakutty, Pravin Kumar Singh. Motion(s) referred to Daniel E. Knowles, III. (Attachments: # 1 Proposed Order, # 2 Proposed Pleading)(Reference: 13−6218, 13−6219, 13−6220, 13−6221, 14−732)(Colby, Eben) (Entered: 08/22/2014)
315 ANSWER to 200 Amended Complaint with Jury Demand by Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C. (Reference: 13−6218)(Cerniglia, Timothy) Modified on 8/25/2014 (gec). (Entered: 08/24/2014)
316 ORDER granting 314 Motion for Leave to File Reply Memorandum. Signed by Magistrate Judge Daniel E. Knowles, III on 8/25/14. (Reference: 13−6218; 13−6219; 13−6220; 13−6221; 14−732)(plh) (Entered: 08/25/2014)
317 REPLY Memorandum in Support of Motion filed by All Plaintiffs re 299 MOTION to Quash Signal's Bank Records Subpoenas. (Reference: 13−6218; 13−6219; 13−6220; 13−6221; 14−732)(plh) (Entered: 08/25/2014)

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08/26/2014 08/27/2014 08/28/2014 08/28/2014 08/28/2014 08/28/2014 08/29/2014 08/29/2014 08/29/2014 08/29/2014 09/06/2014
09/08/2014 09/08/2014
09/08/2014
09/08/2014

318 EXPARTE/CONSENT MOTION to Enroll as Counsel of Record Mitchell Hasenkampf by Signal International, Inc., Signal International, LLC. (Attachments: # 1 Proposed Order)(Reference: 13−6218, 13−6219, 13−6220, 13−6221 & 14−732)(Hangartner, Erin) (Entered: 08/26/2014)
319 Minute Order. Proceedings held before Magistrate Judge Daniel E. Knowles, III: Motion Hearing held on 8/27/2014, taking under advisement 299 MOTION to Quash Signal's Bank Records Subpoenas. (Reference: All cases)(lag) (Entered: 08/27/2014)
320 ANSWER to 199 Amended Complaint with Jury Demand by Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C. (Reference: 13−6219)(Cerniglia, Timothy) (Entered: 08/28/2014)
321 ANSWER to 198 Amended Complaint,, with Jury Demand by Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C..(Reference: 13−6221)(Cerniglia, Timothy) (Entered: 08/28/2014)
322 ORDER granting 318 Motion to Enroll Attorney Mitchell Hasenkampf as Counsel of Record for Signal International LLC and Signal International, Inc. Signed by Judge Susie Morgan. (Reference: All Cases)(bwn) (Entered: 08/28/2014)
323 ANSWER to 201 Amended Complaint, with Jury Demand by Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C..(Reference: 13−6220)(Cerniglia, Timothy) (Entered: 08/28/2014)
324 NOTICE by Signal International, Inc., Signal International, LLC of Expert Witness Disclosure. (Reference: 13−6218, 13−6219, 13−6220, 13−6221 & 14−732)(Hangartner, Erin) (Entered: 08/29/2014)
325 NOTICE of Expert Witness Disclosure by Burnett Defendants. (Reference: 13−6218, 12−6219, 13−6220, 13−6221; 14−732)(Cerniglia, Timothy) (Entered: 08/29/2014)
326 AMENDED SCHEDULING ORDER. Signed by Judge Susie Morgan on 8/29/2014.(Reference: All Cases)(bwn) (Entered: 09/02/2014)
329 Minute Entry for proceedings held before Judge Susie Morgan: Telephone Status Conference held on 8/29/2014. (Reference: All Cases)(bwn) (Entered: 09/08/2014)
327 MOTION for Protective Order by Signal International, Inc., Signal International, LLC. Motion set for 9/24/2014 10:00 AM before Judge Susie Morgan. (Attachments: # 1 Memorandum in Support, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F, # 8 Notice of Submission)(Reference: 13−6218, 13−6219, 13−6220, 13−6221 & 14−732)(Hangartner, Erin) Modified on 9/8/2014 to remove referral (bwn). (Entered: 09/06/2014)
328 EXPARTE/CONSENT MOTION for Extension of Time to Exchange Exhibit Lists by Sachin Dewan and Dewan Consultants Pvt. Ltd. (Attachments: # 1 Proposed Order)(Reference: 13−6218, 13−6219, 13−6220, 13−6221, 14−472)(Shapiro, Stephen) (Entered: 09/08/2014)
330 TRANSCRIPT of Motion Hearing held on April 29, 2014 before Judge Susie Morgan. Court Reporter/Recorder Cathy Pepper, Telephone number 504−589−7779. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Recorder before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Parties have 21 days from the filing of this transcript to file with the Court a Redaction Request. Release of Transcript Restriction set for 12/8/2014. (Reference: All Cases)(rsg) (Entered: 09/08/2014)
331 ORDER − IT IS ORDERED that any opposition to the 327 Motion for Protective Order be filed in the record by September 11, 2014. IT IS FURTHER ORDERED that a telephone status conference is SET for September 16, 2014 at 10:00 a.m. Counsel in all of the above−captioned matters are required to participate. The Court will provide call−in instructions. Signed by Judge Susie Morgan.(Reference: All Cases)(bwn) (Entered: 09/08/2014)
332 ORDER DENYING AS MOOT 308 Motion to Withdraw as Attorney. Signed by Judge Susie Morgan. (Reference: All Cases)(bwn) (Entered: 09/08/2014)

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09/09/2014
09/09/2014 09/09/2014 09/11/2014 09/11/2014
09/12/2014
09/12/2014 09/12/2014 09/12/2014 09/12/2014 09/16/2014 09/16/2014 09/16/2014 09/16/2014

333 MOTION for Partial Summary Judgment Concerning Choice−of−Law by Signal International, Inc., Signal International, LLC. Motion set for 9/24/2014 10:00 AM before Judge Susie Morgan. (Attachments: # 1 Memorandum in Support, # 2 Statement of Contested/Uncontested Facts, # 3 Notice of Submission)(Reference: 13−6218, 13−6219, 13−6220, 13−6221 & 14−732)(Hangartner, Erin) (Entered: 09/09/2014)
334 EXPARTE/CONSENT MOTION to Amend Briefing Schedule Set Out in the Court's 302 Order by George Paily Paulose Chakkiyattil. (Attachments: # 1 Proposed Order)(Reference: 08−1220, 13−6218, 13−6219, 13−6220, 13−6221, 14−732)(Colby, Eben) (Entered: 09/09/2014)
335 ORDER granting 328 Motion for Extension of Deadlines to Exchange Exhibit Lists. Signed by Judge Susie Morgan on 9/9/2014. (Reference: All Cases)(bwn) (Entered: 09/10/2014)
336 ORDER granting 334 Motion to Amend Briefing Schedule Set Out in the Court's 302 Order. Signed by Judge Susie Morgan. (Reference: All Cases)(bwn) (Entered: 09/11/2014)
337 EXPARTE/CONSENT MOTION to File Opposition to Signal's Motion for a Protective Order and Related Exhibits Under Seal by All Plaintiffs. (Attachments: # 1 Memorandum in Support, # 2 Proposed Order, # 3 Notice of Submission)(Reference: 08−1220; 13−6218; 13−6219; 13−6220; 13−6221; 14−0732)(Colby, Eben) Modified on 9/12/2014 to remove submission info (bwn). (Additional attachment(s) added on 9/12/2014: # 4 Proposed Pleading, # 5 Proposed Exhibit 1, # 6 Proposed Exhibit 2, # 7 Proposed Exhibit 3, # 8 Proposed Exhibit 4, # 9 Proposed Exhibit 5) (bwn). (Entered: 09/11/2014)
338 Correction of Docket Entry by Clerk re 337 MOTION to File Opposition to Signal's Motion for a Protective Order and Related Exhibits Under Seal − Filing attorney should have selected 'Yes' at the question 'Is this an Exparte/Consent Motion Y/N?'. Exparte/Consent motions are not set for submission. Clerk has removed submission date. (Reference: All Cases)(bwn) (Entered: 09/12/2014)
339 Witness List by All Plaintiffs. (Reference: 13−6218, 13−6219, 13−6220, 13−6221, 14−732)(Arvelo, Jose) (Entered: 09/12/2014)
340 Witness List by Signal International, Inc., Signal International, LLC. (Reference: 13−6218, 13−6219, 13−6220, 13−6221 & 14−732)(Hangartner, Erin) (Entered: 09/12/2014)
341 Witness List by Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C. (Reference: 13−6219)(Cerniglia, Timothy) (Entered: 09/12/2014)
342 Witness List by Sachin Dewan, Dewan Consultants Pvt. Ltd. (Reference: 13−6218, 13−6219, 13−6220, 13−6221, 14−473)(Shapiro, Stephen) (Entered: 09/12/2014)
343 ORDER granting 337 Motion to File Opposition to Signal's Motion for a Protective Order and Related Exhibits Under Seal. Signed by Judge Susie Morgan. (Reference: All Cases)(bwn) (Entered: 09/16/2014)
344 RESPONSE/MEMORANDUM in Opposition re 327 MOTION for Protective Order by All Plaintiffs. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5) (Reference: All Cases)(bwn) (Entered: 09/16/2014)
345 ORDER granting in part 299 Motion to Quash as outlined herein. Signed by Magistrate Judge Daniel E. Knowles, III on 9/16/2014. (Reference: ALL CASES)(caa) (Entered: 09/16/2014)
346 RESPONSE/MEMORANDUM in Opposition filed by Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C. re 333 MOTION for Partial Summary Judgment Concerning Choice−of−Law . (Attachments: # 1 Statement of Contested/Uncontested Facts)(Reference: 13−6218, 13−6219, 13−6220, 13−6221, 14−732)(Cerniglia, Timothy) (Entered: 09/16/2014)

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09/16/2014 09/16/2014 09/16/2014 09/16/2014 09/17/2014
09/18/2014
09/19/2014
09/19/2014 09/19/2014 09/19/2014 09/19/2014 09/24/2014 09/24/2014

347 RESPONSE/MEMORANDUM in Opposition filed by All Plaintiffs re 333 MOTION for Partial Summary Judgment Concerning Choice−of−Law . (Attachments: # 1 Statement of Contested/Uncontested Facts)(Reference: 13−6219, 13−6220, 13−6221, 14−732)(Colby, Eben) (Entered: 09/16/2014)
348 RESPONSE/MEMORANDUM in Opposition filed by Thampy Putham Parambil Edicula, Sabu Puthukkuttumel Veede Krishnakutty re 333 MOTION for Partial Summary Judgment Concerning Choice−of−Law . (Reference: 2:13−cv−06220)(Aiello, Justin) (Entered: 09/16/2014)
349 RESPONSE/MEMORANDUM in Opposition filed by Sachin Dewan and Dewan Consultants Pvt. Ltd. re 333 MOTION for Partial Summary Judgment Concerning Choice−of−Law . (Reference: 13−6218, 13−6219, 13−6220, 13−6221, 14−472)(Shapiro, Stephen) (Entered: 09/16/2014)
368 Minute Entry for proceedings held before Judge Susie Morgan: Telephone Conference held on 9/16/2014. (Reference: All Cases)(bwn) (Entered: 10/01/2014)
350 TRANSCRIPT of Status Conference held on August 29, 2014 before Judge Susie Morgan. Court Reporter/Recorder Toni Tusa, Telephone number 504−589−7778. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Recorder before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Parties have 21 days from the filing of this transcript to file with the Court a Redaction Request. Release of Transcript Restriction set for 12/16/2014. (Reference: All Cases)(rsg) (Entered: 09/17/2014)
351 MOTION to Stay re 307 ORDER AND REASONS granting 144 Motion for Protective Order and to Certify Orders for Interlocutory Appeal. by Signal International, Inc., Signal International, LLC. Motion set for 10/8/2014 10:00 AM before Judge Susie Morgan. (Attachments: # 1 Memorandum in Support, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Notice of Submission)(Reference: 13−6218, 13−6219, 13−6220, 13−6221 & 14−732)(Hangartner, Erin) Modified on 9/19/2014 to remove referral (bwn). (Entered: 09/18/2014)
352 Correction of Docket Entry by Clerk re 351 MOTION to Stay re 307 Order on Motion for Protective Order, MOTION To Certify Order for Interlocutory Appeal Pursuant to 28 U.S.C. 1292(b) − Filing attorney incorrectly changed 'N' to 'Y' at the question 'Is this motion to be decided by the Magistrate Judge Y/N?'. This motion will be decided by the District Judge. Clerk took corrective action. (Reference: All Cases)(bwn) (Entered: 09/19/2014)
353 Exhibit List by Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C. (Reference: 13−6218)(Cerniglia, Timothy) (Entered: 09/19/2014)
354 Exhibit List by Signal International, Inc., Signal International, LLC. (Reference: 13−6218, 13−6219, 13−6220, 13−6221 & 14−732)(Hangartner, Erin) (Entered: 09/19/2014)
355 Exhibit List by All Plaintiffs. (Reference: 13−6218, 13−6219, 13−6220, 13−6221 & 14−732)(Adams, Daniel) (Entered: 09/19/2014)
356 Exhibit List by Sachin Dewan, Dewan Consultants Pvt. Ltd.. (Reference: 13−6218)(Shapiro, Stephen) (Entered: 09/19/2014)
357 EXPARTE/CONSENT MOTION for Leave to File Reply Memorandum Supporting Motion of Signal For Partial Summary Judgment Concerning Choice−Of−Law by Signal International, Inc., Signal International, LLC. (Attachments: # 1 Proposed Order, # 2 Proposed Pleading)(Reference: 13−6218, 13−6219, 13−6220, 13−6221 & 14−732)(Hangartner, Erin) (Entered: 09/24/2014)
358 EXPARTE/CONSENT MOTION to Continue Submission Date of the Signal Defendants' Motion for Stay and to Certify Orders for Interlocutory Appeal (Rec. Doc. 351) by Lakshmanan Ponnayan Achari, George Paily Paulose Chakkiyattil, Varghese Kurisinkal Devassy, Sabu Puthukkuttumel Veede Krishnakutty, Pravin Kumar Singh. (Attachments: # 1 Proposed Order)(Reference: 13−6218, 13−6219, 13−6220, 13−6221, 14−472)(Arvelo, Jose) Modified on 9/25/2014 (caa). (Entered: 09/24/2014)

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09/25/2014
09/26/2014 09/30/2014 09/30/2014 09/30/2014 09/30/2014 09/30/2014 09/30/2014 09/30/2014 10/01/2014 10/01/2014
10/01/2014
10/01/2014

359 Correction of Docket Entry by Clerk re 358 MOTION for Extension of Deadlines to Change Submission Date of the Signal Defendants' Motion for Stay and to Certify Orders for Interlocutory Appeal (Rec. Doc. 351). Filing attorney selected incorrect event. Correct event is MOTION to Continue. Clerk took corrective action by changing the event. No further action necessary at this time. (Reference: ALL CASES)(caa) (Entered: 09/25/2014)
360 ***DEFICIENT*** EXPARTE/CONSENT MOTION for Extension of Deadlines to Determine Taking of Video Conference Depositions by Sachin Dewan and Dewan Consultants Pvt. Ltd. (Attachments: # 1 Proposed Order)(Reference: 13−6218, 13−6219, 13−6220, 13−6221, 14−472)(Shapiro, Stephen) Modified on 9/30/2014 (bwn). (Entered: 09/26/2014)
361 ORDER granting 357 Motion for Leave to File Reply Memorandum Supporting Motion of Signal For Partial Summary Judgment Concerning Choice−Of−Law. Signed by Judge Susie Morgan. (Reference: All Cases)(bwn) (Entered: 09/30/2014)
362 REPLY to Response to Motion filed by Signal International, Inc., Signal International, LLC re 333 MOTION for Partial Summary Judgment Concerning Choice−of−Law. (Reference: All Cases)(bwn) (Entered: 09/30/2014)
363 ORDER Granting in Part 358 Motion to Continue Submission Date of the Signal Defendants' Motion for Stay and to Certify Orders for Interlocutory Appeal (Rec. Doc. 351). Oppositions are due by October 8, 2014. Replies are due by October 13, 2014. Signed by Judge Susie Morgan. (Reference: All Cases)(bwn) (Entered: 09/30/2014)
364 EXPARTE/CONSENT MOTION to Appear Pro Hac Vice James L. Cornblatt (Filing fee $ 100 receipt number 053L−4609080) by Signal International, Inc., Signal International, LLC. (Attachments: # 1 Exhibit 1 − Declaration of James L. Cornblatt, # 2 Exhibit 2 − Certificate of Good Standing, # 3 Proposed Order)(Reference: 13−6218, 13−6219, 13−6220, 13−6221 & 14−732)(Bollman, Patricia) (Entered: 09/30/2014)
365 Witness List by All Plaintiffs. (Reference: 13−6218, 13−6219, 13−6220, 13−6221, 14−732)(Colby, Eben) (Entered: 09/30/2014)
366 Witness List by Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C. (Reference: 13−6218)(Cerniglia, Timothy) (Entered: 09/30/2014)
372 ANSWER to Complaint by Billy R Wilks. (Attachments: # 1 Index to Exhibits, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Cover Letter, # 6 Envelope)(Reference: 14−1818)(bwn) (Entered: 10/02/2014)
367 ORDER granting 364 Motion to Appear Pro Hac Vice as to James L. Cornblatt. Signed by Judge Susie Morgan. (Reference: All Cases)(bwn) (Entered: 10/01/2014)
369 ORDER CONSOLIDATING CASES − IT IS ORDERED that Thomas v. Signal (No. 14−1818) is CONSOLIDATED with Achari v. Signal (No. 13−6218 c/w 13−6219, 13−6220, 13−6221, 14−732). All subsequent pleadings shall be filed in the lead case (No. 13−6218) only. IT IS FURTHER ORDERED that the ESI Protocol and Clawback Order in the Achari Cases shall also apply to the Thomas Case. Signed by Judge Susie Morgan.(Reference: All Cases)(bwn) (Entered: 10/01/2014)
370 ANSWER to Complaint with Jury Demand , CROSSCLAIM with Jury Demand against Malvern C. Burnett, Sachin Dewan, Dewan Consultants Pvt. Ltd., Global Resources Inc, Gulf Coast Immigration Law Center, L.L.C., Indo−Amerisoft LLC((13−6220)), J&M Associates, Inc. of Mississippi, J&M Marine & Industrial, LLC, Law Offices of Malvern C. Burnett, A.P.C., Michael Pol, Kurella Rao, Billy R Wilks by Signal International, LLC, Signal International, Inc., Signal International Texas, G.P., Signal International Texas, L.P..(Reference: 14−1818)Attorney Erin Casey Hangartner added to party Signal International Texas, G.P.(pty:dft), Attorney Erin Casey Hangartner added to party Signal International Texas, L.P.(pty:dft).(Hangartner, Erin) (Entered: 10/01/2014)
371 EXPARTE/CONSENT MOTION for Leave to File Answer Out of Time by Sachin Dewan((13−6219)), Sachin Dewan, Dewan Consultants Pvt. Ltd.((13−6220)), Dewan Consultants Pvt. Ltd.. (Attachments: # 1 Proposed Order, # 2 Proposed Pleading)(Reference: 14−1818)(Shapiro, Stephen) (Entered: 10/01/2014)

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10/02/2014 10/02/2014 10/02/2014
10/02/2014 10/02/2014 10/03/2014 10/03/2014 10/03/2014
10/03/2014 10/03/2014 10/03/2014 10/03/2014
10/04/2014

373 MOTION for Extension of Discovery Deadlines by Signal International, Inc., Signal International, LLC. Motion set for 10/22/2014 10:00 AM before Judge Susie Morgan. (Attachments: # 1 Memorandum in Support, # 2 Exhibit A − Email Exchange, # 3 Notice of Submission, # 4 Proposed Order)(Reference: 13−6218, 13−6219, 13−6220, 13−6221, 14−732 & 14−1818)(Hangartner, Erin) (Entered: 10/02/2014)
374 EXPARTE/CONSENT Consent MOTION to Expedite Signal's Motion for Extension of Discovery Deadline by Signal International, Inc., Signal International, LLC. (Attachments: # 1 Proposed Order)(Reference: 13−6218, 13−6219, 13−6220, 13−6221, 14−732 & 14−1818)(Hangartner, Erin) (Entered: 10/02/2014)
375 MOTION for Extension of Time to Determine Taking of Video Conference Depositions by Sachin Dewan, Sachin Dewan, Dewan Consultants Pvt. Ltd., Dewan Consultants Pvt. Ltd. Motion set for 10/22/2014 10:00 AM before Judge Susie Morgan. (Attachments: # 1 Memorandum in Support, # 2 Proposed Order, # 3 Notice of Submission)(Reference: 13−6218, 13−6219, 13−6220, 13−6221, 14−472, 14−1818)(Shapiro, Stephen) (Entered: 10/02/2014)
376 EXPARTE/CONSENT MOTION to Join Signal's Motion for Stay and to Certify Orders for Interlocutory Appeal by Sachin Dewan, Dewan Consultants Pvt. Ltd. (Attachments: # 1 Proposed Order)(Reference: 13−6218, 13−6219, 13−6220, 13−6221, 14−472, 14−1818)(Shapiro, Stephen) (Entered: 10/02/2014)
377 EXPARTE/CONSENT MOTION to Expedite Hearing on Motion to Determine Whether Video Conference Depositions of India Witness Will be Taken by Sachin Dewan, Sachin Dewan, Dewan Consultants Pvt. Ltd., Dewan Consultants Pvt. Ltd.. (Attachments: # 1 Proposed Order)(Reference: 13−6218, 13−6219, 13−6220, 13−6221, 14−472, 14−1818)(Shapiro, Stephen) (Entered: 10/02/2014)
378 ORDER granting 371 Motion for Leave to File Answer Out of Time. Signed by Judge Susie Morgan. (Reference: 14−1818)(bwn) (Entered: 10/03/2014)
379 ANSWER to Complaint by Sachin Dewan, Dewan Consultants Pvt. Ltd.(Reference: 14−1818)(bwn) (Entered: 10/03/2014)
380 ORDER granting 375 Motion for Extension of Deadlines to Determine Taking of Video Conference Depositions. IT IS ORDERED that the deadline for Sachin Dewan and Dewan Consultants Pvt. Ltd. to determine whether video conference depositions of witnesses in India will go forward is hereby extended from September 26, 2014 to October 10, 2014. Signed by Judge Susie Morgan. (Reference: All Cases)(bwn) (Entered: 10/03/2014)
381 ORDER finding as moot 377 Motion to Expedite Hearing on Motion to Determine Whether Video Conference Depositions of India Witness Will be Taken. Signed by Judge Susie Morgan. (Reference: All Cases)(bwn) (Entered: 10/03/2014)
382 ORDER granting 376 Motion to Join Signal's Motion for Stay and to Certify Orders for Interlocutory Appeal. Signed by Judge Susie Morgan. (Reference: All Cases)(bwn) (Entered: 10/03/2014)
383 ORDER granting 374 Motion to Expedite Signal's Motion for Extension of Discovery Deadline. Oppositions are due by the end of day on October 6, 2014. Signed by Judge Susie Morgan. (Reference: All Cases)(bwn) (Entered: 10/03/2014)
384 MOTION to Certify Orders for Interlocutory Appeal and to Join Signal's Motion for Stay and to Certify Orders for Interlocutory Appeal by Malvern C. Burnett, Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C., Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C., Law Offices of Malvern C. Burnett, A.P.C. Motion set for 10/22/2014 10:00 AM before Judge Susie Morgan. (Attachments: # 1 Memorandum in Support, # 2 Proposed Order, # 3 Notice of Submission)(Reference: 13−6218,13−6219, 13−6220; 13−6221; 14−427, 14−1818)(Cerniglia, Timothy) Modified on 10/6/2014 to edit submission info (bwn). (Entered: 10/03/2014)
385 EXPARTE/CONSENT MOTION to Substitute Notice of Submission by Malvern C. Burnett, Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C., Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C., Law Offices of Malvern C. Burnett, A.P.C.. (Attachments: # 1 Proposed Pleading, # 2

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10/06/2014 10/07/2014 10/08/2014 10/09/2014 10/10/2014 10/14/2014
10/14/2014
10/16/2014 10/21/2014 10/21/2014 10/21/2014 10/22/2014 10/22/2014 10/22/2014 10/28/2014 10/30/2014

Proposed Order)(Reference: 13−6218,13−6219,13−6220,13−6221, 14−732,14−1818)(Cerniglia, Timothy) (Entered: 10/04/2014)
386 RESPONSE/MEMORANDUM in Opposition filed by All Plaintiffs re 373 MOTION for Extension of Discovery Deadlines . (Reference: 13−6218)(Adams, Daniel) (Entered: 10/06/2014)
387 ORDER Denying as Moot 385 Motion to Substitute Notice of Submission. Signed by Judge Susie Morgan. (Reference: All Cases)(bwn) (Entered: 10/07/2014)
388 RESPONSE/MEMORANDUM in Opposition filed by Plaintiffs re 351 MOTION to Stay re 307 Order on Motion for Protective Order, MOTION To Certify Order for Interlocutory Appeal Pursuant to 28 U.S.C. 1292(b) . (Reference: 13−6218)(Grimsal, A.) (Entered: 10/08/2014)
389 ORDER denying 373 Motion for Extension of Discovery Deadlines. Signed by Judge Susie Morgan. (Reference: All Cases)(bwn) (Entered: 10/09/2014)
390 Amended Witness List by Sachin Dewan, Sachin Dewan, Dewan Consultants Pvt. Ltd., Dewan Consultants Pvt. Ltd.. (Reference: 13−6218, 13−6219, 13−6220, 13−6221, 14−472, 14−1818)(Shapiro, Stephen) (Entered: 10/10/2014)
391 EXPARTE/CONSENT MOTION for Leave to File Reply Memorandum in Support of Motion for Stay and to Certify Orders for Interlocutory Appeal Pursuant to 28 U.S.C. 1292(b) of Signal Defendants by Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Signal International, LLC. (Attachments: # 1 Proposed Order, # 2 Proposed Pleading)(Reference: 13−6218, 13−6219, 13−6220, 13−6221, 14−732 & 14−1818)(Hangartner, Erin) (Entered: 10/14/2014)
392 ORDER AND REASONS denying 351 Motion to Certify for Interlocutory Appeal or Alternatively to Stay Pending Application for Mandamus Relief; denying 351 Motion ; denying 384 MOTION to Certify Orders for Interlocutory Appeal and to Join Signal's Motion for Stay and to Certify Orders for Interlocutory Appeal. Signed by Judge Susie Morgan. (Reference: 13−6218, 13−6219, 13−6220, 13−6221, 14−732)(bwn) (Entered: 10/14/2014)
393 ORDERED that 391 Motion for Leave to File Reply is DENIED as untimely. Signed by Judge Susie Morgan. (Reference: 13−6218, 13−6219, 13−6220, 13−6221, 14−732 & 14−1818)(cml) (Entered: 10/16/2014)
394 EXPARTE/CONSENT MOTION to Appear Pro Hac Vice for Zachary Lance Rowen (Filing fee $ 100 receipt number 053L−4630232) by Plaintiffs . (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Proposed Order)(Reference: 13−6218)(Grimsal, A.) (Entered: 10/21/2014)
395 EXPARTE/CONSENT MOTION to Appear Pro Hac Vice for Sadie H. Diaz (Filing fee $ 100 receipt number 053L−4630258) by Plaintiffs. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Proposed Order)(Reference: 13−6218)(Grimsal, A.) (Entered: 10/21/2014)
396 EXPARTE/CONSENT MOTION to Appear Pro Hac Vice for Eric L. Taffet (Filing fee $ 100 receipt number 053L−4630281) by Plaintiffs. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Proposed Order)(Reference: 13−6218)(Grimsal, A.) (Entered: 10/21/2014)
397 ORDER granting 394 Motion to Appear Pro Hac Vice as to Zachary L. Rowen. Signed by Judge Susie Morgan. (Reference: 13−6218)(bwn) (Entered: 10/22/2014)
398 ORDER granting 395 Motion to Appear Pro Hac Vice as to Sadie Holzman Diaz. Signed by Judge Susie Morgan. (Reference: 13−6218)(bwn) (Entered: 10/22/2014)
399 ORDER granting 396 Motion to Appear Pro Hac Vice as to Eric L. Taffet. Signed by Judge Susie Morgan. (Reference: 13−6218)(bwn) (Entered: 10/22/2014)
400 Minute Entry for proceedings held before Judge Susie Morgan: Telephone Status Conference held on 10/28/2014. (Reference: All Cases)(bwn) (Entered: 10/29/2014)
408 Minute Entry for proceedings held before Judge Susie Morgan: Status Conference held on 10/30/2014. (Reference: All Cases)(bwn) (Entered: 12/02/2014)

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 218 of 250

11/06/2014 11/07/2014 11/10/2014 11/10/2014 11/14/2014 11/19/2014 11/21/2014 11/25/2014
12/02/2014 12/02/2014 12/02/2014 12/02/2014 12/29/2014
12/31/2014

401 EXPARTE/CONSENT MOTION to Appear Pro Hac Vice for Renee E. Plexousakis (Filing fee $ 100 receipt number 053L−4649482) by Plaintiffs. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Proposed Order)(Reference: 13−6218)(Grimsal, A.) (Entered: 11/06/2014)
402 ORDER − IT IS ORDERED that a telephone status conference is SET in the above captioned matters for November 10, 2014 at 3:00 p.m. to discuss the possibility of mediation in the David case. Signed by Judge Susie Morgan.(Reference: All Cases)(bwn) (Entered: 11/07/2014)
403 ORDER granting 401 Motion to Appear Pro Hac Vice as to Renee E. Plexousakis. Signed by Judge Susie Morgan on 11/10/2014. (Reference: 13−6218)(my) (Entered: 11/13/2014)
413 Minute Entry for proceedings held before Judge Susie Morgan: Telephone Status Conference held on 11/10/2014. (Reference: All Cases)(bwn) (Entered: 12/08/2014)
404 EXPARTE/CONSENT MOTION to Withdraw Craig A. Batchelor as Attorney by Plaintiffs. (Attachments: # 1 Proposed Order)(Reference: 13−6218)(Grimsal, A.) (Entered: 11/14/2014)
405 ORDER granting 404 Motion to Withdraw as Attorney. Attorney Craig Alan Batchelor terminated. Signed by Judge Susie Morgan on 11/19/2014. (Reference: 13−6218)(bwn) (Entered: 11/20/2014)
406 EXPARTE/CONSENT MOTION to Withdraw Scott W. Clark as Attorney by Thampy Putham Parambil Edicula, Sabu Puthukkuttumel Veede Krishnakutty. (Attachments: # 1 Proposed Order)(Reference: 13−6220)(Grimsal, A.) (Entered: 11/21/2014)
407 EXPARTE/CONSENT Consent MOTION for Leave to File Amended Answer to Plaintiffs' Original Complaint by Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Signal International, LLC. (Attachments: # 1 Proposed Order, # 2 Proposed Pleading)(Reference: 14−1818)(Hangartner, Erin) (Entered: 11/25/2014)
409 ORDER granting 406 Motion to Withdraw as Attorney. Attorney Scott W. Clark terminated. Signed by Judge Susie Morgan. (Reference: 13−6220)(bwn) (Entered: 12/02/2014)
410 ORDER granting 407 Motion for Leave to File Amended Answer to Plaintiffs' Original Complaint. Signed by Judge Susie Morgan. (Reference: 14−1818)(bwn) (Entered: 12/02/2014)
411 AMENDED ANSWER to Thomas Plaintiffs' Complaint by Signal International Texas GP, LLC, Signal International Texas, L.P., Signal International, Inc., Signal International, LLC. (Reference: 14−1818)(bwn) (Entered: 12/02/2014)
412 ORDER − The parties shall adhere to the deadlines herein. Signed by Judge Susie Morgan on 11/30/2014. (Attachments: # 1 Revised Pre−Trial Notice)(Reference: All Cases)(bwn) (Entered: 12/03/2014)
414 EXPARTE/CONSENT MOTION to Appear Pro Hac Vice for Mark H. Churchill (Filing fee $ 100 receipt number 053L−4699251) by Thampy Putham Parambil Edicula, Sabu Puthukkuttumel Veede Krishnakutty. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Proposed Order)(Reference: 13−6220)(Grimsal, A.) (Entered: 12/29/2014)
415 THOMAS PLAINTIFFS UNOPPOSED NOTICE OF FIRST SET OF PROPOSED PLAINTIFFS FOR TRIAL by Ganapathi Rao Akkireddi, Davis Antony, Saji Chettiyara Baby, Sarma Venkata Satyanarayana Bhiri, Venkatarao Buridi, Sunny Cherian, Philip Pindakadavil George, Zakir Husain Ghulam Husain, Mathew Jackson, Gogy Joseph, Joshy Kaiprampattu Joseph, Shanoj Joseph, Srinu Kalla, Joseph Thomas Kanjiraparambil, Subranarayanan Karuppiah, Maheshwara Rao Molletti, Sivakumar Ramakrishnan Nair, Reghunadhan Palachuvattilpu Narayanannair, Bhaskararao Nimmadala, Babu Karippai Ouseph, Baiju Paul, Rajan Pazhambalakode, Kantibhai Khemabhai Prajapati, Ravi Thammina, Assari Krishnan Thankappan, George Kutty Puthiya P Thomas, David Raju Tuloori, Satyanarayana Vangapandu, Yacob Thachil Varghese, Antoney Tharayil Xavier . (Reference: 14−1818)(Parver, Jane) (Entered:

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12/31/2014 12/31/2014 12/31/2014 12/31/2014 01/05/2015 01/06/2015 01/06/2015 01/06/2015 01/06/2015 01/15/2015 01/20/2015

12/31/2014)
416 **DEFICIENT**EXPARTE/CONSENT MOTION for Extension of Deadlines (Modify the Scheduling Order) by Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Signal International, LLC. (Attachments: # 1 Memorandum in Support, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Proposed Order)(Reference: 13−6219)(Hangartner, Erin) Modified on 1/2/2015 (my). (Entered: 12/31/2014)
417 **DEFICIENT**EXPARTE/CONSENT MOTION for Extension of Deadlines (Modify the Scheduling Order) by Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Signal International, LLC. (Attachments: # 1 Memorandum in Support, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Proposed Order)(Reference: 13−6220)(Hangartner, Erin) Modified on 1/2/2015 (my). (Entered: 12/31/2014)
418 **DEFICIENT**EXPARTE/CONSENT MOTION for Extension of Deadlines (Modify the Scheduling Order) by Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Signal International, LLC. (Attachments: # 1 Memorandum in Support, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Proposed Order)(Reference: 13−6221)(Hangartner, Erin) Modified on 1/2/2015 (my). (Entered: 12/31/2014)
419 **DEFICIENT**EXPARTE/CONSENT MOTION for Extension of Deadlines (Modify the Scheduling Order) by Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Signal International, LLC. (Attachments: # 1 Memorandum in Support, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Proposed Order)(Reference: 14−732)(Hangartner, Erin) Modified on 1/2/2015 (my). (Entered: 12/31/2014)
420 ORDER granting 414 Motion to Appear Pro Hac Vice as to Mark H. Churchill. Signed by Judge Susie Morgan. (Reference: 13−6220)(bwn) (Entered: 01/05/2015)
422 MOTION to Modify the Scheduling Order by Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Signal International, LLC. Motion set for 1/28/2015 10:00 AM before Judge Susie Morgan. (Attachments: # 1 Memorandum in Support, # 2 Notice of Submission, # 3 Exhibit A, # 4 Exhibit B, # 5 Exhibit C, # 6 Exhibit D)(Reference: 13−6219)(Hangartner, Erin) Modified on 1/7/2015 (bwn). (Entered: 01/06/2015)
423 MOTION to Modify the Scheduling Order by Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Signal International, LLC. Motion set for 1/28/2015 10:00 AM before Judge Susie Morgan. (Attachments: # 1 Memorandum in Support, # 2 Notice of Submission, # 3 Exhibit A, # 4 Exhibit B, # 5 Exhibit C, # 6 Exhibit D)(Reference: 13−6220)(Hangartner, Erin) (Entered: 01/06/2015)
424 MOTION to Modify the Scheduling Order by Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Signal International, LLC. Motion set for 1/28/2015 10:00 AM before Judge Susie Morgan. (Attachments: # 1 Memorandum in Support, # 2 Notice of Submission, # 3 Exhibit A, # 4 Exhibit B, # 5 Exhibit C, # 6 Exhibit D)(Reference: 13−6221)(Hangartner, Erin) (Entered: 01/06/2015)
425 MOTION to Modify the Scheduling Order by Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Signal International, LLC. Motion set for 1/28/2015 10:00 AM before Judge Susie Morgan. (Attachments: # 1 Memorandum in Support, # 2 Notice of Submission, # 3 Exhibit A, # 4 Exhibit B, # 5 Exhibit C, # 6 Exhibit D)(Reference: 14−732)(Hangartner, Erin) (Entered: 01/06/2015)
426 Supplemental Memorandum filed by All Plaintiffs, in Opposition of 333 MOTION for Partial Summary Judgment Concerning Choice−of−Law . (Reference: 13−6218, 13−6219, 13−6220, 13−6221, 14−732)(Colby, Eben) (Entered: 01/15/2015)
427 EXPARTE/CONSENT MOTION to File Opposition To Signal's Motion To Modify The Scheduling Order And Accompanying Exhibits Under Seal by Plaintiffs.

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01/23/2015
01/23/2015 01/28/2015 01/28/2015 01/29/2015 01/29/2015
01/31/2015 02/04/2015 02/04/2015 02/06/2015

(Attachments: # 1 Memorandum in Support, # 2 Proposed Order)(Reference: 13−6219, 13−6220, 13−6221, 14−732)(Colby, Eben) Modified on 1/21/2015 to edit docket text (bwn). (Additional attachment(s) added on 1/21/2015: # 3 Proposed Pleading, # 4 Declaration of Stephen T. Raptis, # 5 Declaration of Marissa C. Krumm, # 6 Declaration of Jose E. Arvelo, # 7 Exhibit 1, # 8 Declaration of Eben P. Colby, # 9 Exhibit 1, # 10 Exhibit 2, # 11 Exhibit 3, # 12 Exhibit 4, # 13 Exhibit 5, # 14 Exhibit 6, # 15 Exhibit 7, # 16 Exhibit 8) (bwn). (Entered: 01/20/2015)
428 TRANSCRIPT of Status Conference held on February 21, 2014 before Judge Susie Morgan. Court Reporter/Recorder Susan Zielie, Telephone number 504−589−7781. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Recorder before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Parties have 21 days from the filing of this transcript to file with the Court a Redaction Request. Release of Transcript Restriction set for 4/23/2015. (Reference: All Cases)(rsg) (Entered: 01/23/2015)
429 SEALED ORDER denying 327 Motion for Protective Order, as stated herein. Signed by Judge Susie Morgan on 1/19/2015. (Reference: All Cases) (tsf) (Additional attachment(s) added on 1/23/2015: # 1 SEALED Attachment, # 2 SEALED Attachment, # 3 SEALED Attachment, # 4 SEALED Attachment, # 5 SEALED Attachment, # 6 SEALED Attachment) (tsf). (Entered: 01/23/2015)
430 ORDER granting 427 Motion to Seal Opposition To Signal's Motion To Modify The Scheduling Order And Accompanying Exhibits Under Seal. Signed by Judge Susie Morgan on 1/28/2015. (Reference: 13−6219; 13−6220; 13−6221; and 14−732)(bwn) (Entered: 01/28/2015)
431 Opposition to 422 , 423 , 424 and 425 Motions to Modify the Scheduling Order by Plaintiffs. (Attachments: # 1 Declaration of Stephen T. Raptis, # 2 Declaration of Marissa C. Krumm, # 3 Declaration of Jose E. Arvelo, # 4 Exhibit 1, # 5 Declaration of Eben P. Colby, # 6 Exhibit 1, # 7 Exhibit 2, # 8 Exhibit 3, # 9 Exhibit 4, # 10 Exhibit 5, # 11 Exhibit 6, # 12 Exhibit 7, # 13 Exhibit 8) (Reference: 13−6219; 13−6220; 13−6221; and 14−732)(bwn) (Entered: 01/28/2015)
432 Supplemental Memorandum filed by Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Signal International, LLC, in in support of 333 MOTION for Partial Summary Judgment Concerning Choice−of−Law . (Reference: 13−6218, 13−6219, 13−6220, 13−6221 & 14−732)(Hangartner, Erin) (Entered: 01/29/2015)
433 TRANSCRIPT of Telephone Status Conference held on May 21, 2014 before Judge Susie Morgan. Court Reporter/Recorder Susan Zielie, Telephone number 504−589−7781. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Recorder before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Parties have 21 days from the filing of this transcript to file with the Court a Redaction Request. Release of Transcript Restriction set for 4/29/2015. (Reference: 08−1220 & 12−557 & Applies to All Cases)(rsg) (Entered: 01/29/2015)
434 EXPARTE/CONSENT MOTION for Leave to File Reply Brief to Opposition Motion to Modify the Scheduling Order by Signal International Texas GP, LLC, Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc.. Mo (Attachments: # 1 Proposed Order, # 2 Proposed Pleading, # 3 Exhibit)(Reference: 13−6219, 13−6220, 13−6221 & 14−732)(Hangartner, Erin) Modified on 2/2/2015 to remove referral(plh). (Entered: 01/31/2015)
435 ORDER granting 434 Motion for Leave to File Reply Brief to Opposition Motion to Modify the Scheduling Order. Signed by Judge Susie Morgan. (Reference: 14−6219; 13−6220; 13−6221; 14−732)(bwn) (Entered: 02/04/2015)
436 REPLY to Response to Motion filed by Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Signal International, LLC re 425 MOTION to Modify the Scheduling Order. (Attachments: # 1 Exhibit)(Reference: 14−6219; 13−6220; 13−6221; 14−732)(bwn) (Entered: 02/04/2015)
437 TRANSCRIPT of Status Conference held on October 30, 2014 before Judge Susie Morgan. Court Reporter/Recorder Toni Tusa, Telephone number 504−589−7778.

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02/06/2015 02/09/2015 02/11/2015 02/19/2015 02/20/2015 03/02/2015
03/05/2015 03/06/2015 03/10/2015

Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Recorder before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Parties have 21 days from the filing of this transcript to file with the Court a Redaction Request. Applies to all cases. Release of Transcript Restriction set for 5/7/2015. (Reference: 08−1220, 12−557 13−6218 & consolidated cases)(rsg) Modified on 2/6/2015 (rsg). (Entered: 02/06/2015)
438 Supplemental Memorandum filed by All Plaintiffs, in opposition of 424 MOTION to Modify the Scheduling Order, 423 MOTION to Modify the Scheduling Order, 425 MOTION to Modify the Scheduling Order, 422 MOTION to Modify the Scheduling Order Plaintiffs' Sur−Reply. (Reference: 13−6219, 13−6220, 13−6221, 14−732)(Colby, Eben) (Entered: 02/06/2015)
439 ORDER − IT IS ORDERED that due to an ongoing trial, the status conference scheduled in these matters on Wednesday, February 11, 2015 is CONTINUED to Monday, March 2, 2015 at 2:00 p.m. Signed by Judge Susie Morgan on 2/9/2015.(Reference: All Cases)(bwn) (Entered: 02/10/2015)
440 EXPARTE/CONSENT MOTION for Extension of Deadlines to Deliver Rebuttal Expert Reports by Plaintiffs. (Attachments: # 1 Proposed Order)(Reference: 13−6218, 13−6219, 13−6220, 13−6221, 14−732).(Grimsal, A.) Modified on 2/12/2015 to edit docket text (bwn). (Entered: 02/11/2015)
441 ORDER − In anticipation of the status conference on March 2, 2015, at 2:00 p.m.; IT IS ORDERED that the parties submit a joint proposed agenda by February 25, 2015 at 5:00 p.m. Signed by Judge Susie Morgan on 2/18/2015.(Reference: All Cases)(bwn) (Entered: 02/19/2015)
442 ORDER granting 440 Motion for Extension of Deadlines to Deliver Rebuttal Expert Reports. It is therefore ORDERED that the deadline to deliver Plaintiffs rebuttal expert reports in the consolidated Achari cases is extended from February 13, 2015, to February 16, 2015. Signed by Judge Susie Morgan. (Reference: 13−6219, 13−6220, 13−6221, and 14−732)(bwn) (Entered: 02/20/2015)
443 Minute Entry for proceedings held before Judge Susie Morgan: Status Conference held on 3/2/2015. All motions requesting entry of final judgment shall be filed by March 16, 2015. If the Court enters final judgment, all motions for summary judgment regarding claim preclusion and/or issue preclusion shall be filed by May 4, 2015. The parties discussed the motions pending in the EEOC Case. For the reasons stated orally and on the record, EEOC's Motion to Provide Notice and Signal's Countermotion for Sanctions are DENIED. By March 23, 2015, Plaintiffs in each of the consolidated Achari Cases shall provide the Court a summary of their claims in chart format similar to the chart attached to the Sixth Amended Complaint in the David Case. For the reasons stated orally and on the record, Signal's Motions to Continue in the consolidated Achari cases are GRANTED IN PART. The Court will grant Signal additional time to depose Plaintiffs. The status conference currently set for April 1, 2015 at 2:00 p.m. is CONVERTED to a telephone status conference. (Reference: All Cases)(bwn) (Entered: 03/05/2015)
444 ORDER − The parties shall adhere to the deadlines herein. Signed by Judge Susie Morgan on 3/4/2015. (Attachments: # 1 Pre−Trial Notice)(Reference: All Cases)(bwn) (Entered: 03/05/2015)
445 TRANSCRIPT of Status Conference held on March 2, 2015 before Judge Susie Morgan. Court Reporter/Recorder Terri Hourigan, Telephone number 504−589−7775. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Recorder before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Parties have 21 days from the filing of this transcript to file with the Court a Redaction Request. Release of Transcript Restriction set for 6/4/2015. (Reference: All Cases)(rsg) (Entered: 03/06/2015)
446 EXPARTE/CONSENT MOTION for Leave to File Limited Reply to Signal's Opposition to David Plaintiffs' Motion for Entry of Final Judgment by Achari Plaintiffs. (Attachments: # 1 Proposed Order, # 2 Proposed Pleading, # 3 Proposed Exhibit)(Reference: 08−1220)(Grimsal, A.) (Entered: 03/10/2015)

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03/11/2015
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03/12/2015
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03/13/2015
03/16/2015 03/23/2015 03/23/2015 03/23/2015

447 ***DEFICIENT*** EXPARTE/CONSENT OTION to Quash Plaintiffs' Notice to Redepose Signals' Immigration Expert Enrique Gonzalez by Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Signal International, LLC. (Attachments: # 1 Memorandum in Support, # 2 Proposed Order, # 3 Exhibit A, # 4 Exhibit B, # 5 Exhibit C)(Reference: 13−6218, 13−6219, 13−6220, 13−6221 & 14−732)(Hangartner, Erin) Modified on 3/12/2015 (bwn). (Entered: 03/11/2015)
448 MOTION to Quash Plaintiffs' Notice to Redepose Signal's Immigration Expert Enrique Gonzalez by Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Signal International, LLC. Motion(s) referred to Daniel E. Knowles, III. Motion set for 4/8/2015 11:00 AM before Magistrate Judge Daniel E. Knowles III. (Attachments: # 1 Memorandum in Support, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Notice of Submission)(Reference: 13−6218, 13−6219, 13−6220, 13−6221 & 14−732)(Hangartner, Erin) Modified on 3/13/2015 to add referral and edit submission information (bwn). (Entered: 03/12/2015)
449 EXPARTE/CONSENT MOTION to Expedite Hearing on Signal's Motion to Quash Plaintiffs' Notice to Redepose Signal's Immigration Expert Enrique Gonzalez by Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Signal International, LLC. Motion(s) referred to Daniel E. Knowles, III. (Attachments: # 1 Proposed Order)(Reference: 13−6218, 13−6219, 13−6220, 13−6221 & 14−732)(Hangartner, Erin) Modified on 3/13/2015 to add referral (bwn). (Entered: 03/12/2015)
450 ORDER granting 446 Motion for Leave to File Limited Reply to Signal's Opposition to David Plaintiffs' Motion for Entry of Final Judgment. Signed by Judge Susie Morgan. (Reference: All Cases)(bwn) (Entered: 03/12/2015)
451 Limited Reply to Signal's Opposition to the David Plaintiffs' Motion for Entry of Final Judgment by Consolidated Achari Plaintiffs. (Attachments: # 1 Exhibit)(Reference: All Cases)(bwn) (Entered: 03/12/2015)
452 Correction of Docket Entry by Clerk re 448 MOTION to Quash Plaintiffs' Notice to Redepose Signal's Immigration Expert Enrique Gonzalez, 449 MOTION to Expedite Hearing on Signal's Motion to Quash Plaintiffs' Notice to Redepose Signal's Immigration Expert Enrique Gonzalez − Filing attorney should have changed 'N' to 'Y' at the question 'Is this motion to be decided by the Magistrate Judge Y/N?'. This motion will be decided by the Magistrate Judge. Clerk took corrective action. (Reference: All Cases)(bwn) (Entered: 03/13/2015)
453 ORDER Setting ORAL Hearing on 448 MOTION to Quash Plaintiffs' Notice to Redepose Signal's Immigration Expert Enrique Gonzalez. The 449 MOTION to Expedite is moot. ORDERED that the 448 MOTION to Quash Plaintiffs' Notice to Redepose Signal's Immigration Expert Enrique Gonzalez is SET FOR ORAL HEARING 4/1/2015 11:00 AM before Magistrate Judge Daniel E. Knowles III. Signed by Magistrate Judge Daniel E. Knowles, III on 3/13/15.(Reference: All Cases)(plh) (Entered: 03/13/2015)
454 MOTION to Compel Signal To Meet And Confer In Good Faith Regarding Privilege Issues by Achari Plaintiffs. Motion set for 4/8/2015 10:00 AM before Judge Susie Morgan. (Attachments: # 1 Memorandum in Support, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Notice of Submission)(Reference: 13−6218, 13−6219, 13−6220, 13−6221, 14−732)(Colby, Eben) (Entered: 03/16/2015)
455 Summary of Claims in Second Amended Complaint (Chart) by Plaintiffs. (Reference: 13−6218)(Grimsal, A.) Modified on 3/24/2015 to edit docket text (bwn). (Entered: 03/23/2015)
456 Summary of Claims in First Amended Complaint (Chart) by Plaintiffs (Reference: 13−6221)(Grimsal, A.) Modified on 3/24/2015 to edit docket text (bwn). (Entered: 03/23/2015)
457 Summary of Claims in Amended Complaint (Chart) by Plaintiffs (Reference: 13−6219)(Grimsal, A.) Modified on 3/24/2015 to edit docket text (bwn). (Entered: 03/23/2015)

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04/01/2015

458 Summary of Claims (Chart) by Plaintiffs. (Reference: 14−732)(Grimsal, A.) Modified on 3/24/2015 to edit docket text (bwn). (Entered: 03/23/2015)
459 Summary of Claims in First Amended Complaint (Chart) by Plaintiffs. (Reference: 13−6220)(Aiello, Justin) Modified on 3/24/2015 to edit docket text (bwn). (Entered: 03/23/2015)
460 Summary of Claims in Complaint (Chart) by Plaintiffs. (Reference: 14−1818)(Szivos, Thomas) Modified on 3/24/2015 to edit docket text (bwn). (Entered: 03/23/2015)
461 RESPONSE/MEMORANDUM in Opposition filed by Achari Plaintiffs re 448 MOTION to Quash Plaintiffs' Notice to Redepose Signal's Immigration Expert Enrique Gonzalez /Plaintiffs' Opposition to Signal's Motion to Quash Plaintiffs' Notice of Deposition and Subpoena to Signal's Immigration Expert Enrique Gonzalez,. (Attachments: # 1 Declaration of Eric B. Chen in Support of Plaintiffs' Opposition to Signal's Motion to Quash Plaintiffs' Notice of Deposition and Subpoena to Signal's Immigration Expert Enrique Gonzalez, # 2 Exhibit A−K to Declaration of Eric B. Chen)(Reference: 13−6219, 13−6220, 13−6221, 14−732)(Raptis, Stephen) Modified on 3/25/2015 (gec). (Entered: 03/24/2015)
462 ORDER − In anticipation of the telephone status conference on April 1, 2015 at 2:00 p.m.; IT IS ORDERED that the parties submit a joint proposed agenda by March 30, 2015 at 12:00 p.m. Signed by Judge Susie Morgan.(Reference: All Cases)(bwn) (Entered: 03/26/2015)
463 RESPONSE/MEMORANDUM in Opposition filed by Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Signal International, LLC re 454 MOTION to Compel Signal To Meet And Confer In Good Faith Regarding Privilege Issues . (Attachments: # 1 Exhibit A)(Reference: 13−6218, 13−6219, 13−6220, 13−6221 & 14−732)(Hangartner, Erin) (Entered: 03/27/2015)
464 Minute Order. Proceedings held before Magistrate Judge Daniel E. Knowles, III: Motion Hearing held on 4/1/2015 re 448 MOTION to Quash Plaintiffs' Notice to Redepose Signal's Immigration Expert Enrique Gonzalez filed by Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Signal International, LLC. ORDERED that Signal's 448 MOTION to Quash Plaintiffs' Notice to Redepose Signal's Immigration Expert Enrique Gonzalez is DENIED IN PART as set forth in document. (Reference: All Cases)(plh) (Entered: 04/01/2015)
465 MOTION to Exclude Testimony and Report of Proffered Expert Ron McAlear by Plaintiffs. Motion set for 5/6/2015 10:00 AM before Judge Susie Morgan. (Attachments: # 1 Memorandum in Support, # 2 Exhibit A, # 3 Exhibit B, # 4 Notice of Submission)(Reference: 13−6218; 13−6219; 13−6220; 13−6221; 14−732)(Colby, Eben) Modified on 4/2/2015 (bwn). (Entered: 04/01/2015)
466 MOTION to Exclude Testimony and Report of Proffered Expert Ronald Signorino by Pravin Kumar Singh, Radhakrishnan Nair Mangalathu Vasukuttan. Motion set for 5/6/2015 10:00 AM before Judge Susie Morgan. (Attachments: # 1 Memorandum in Support, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4, # 6 Notice of Submission)(Reference: 13−6218; 13−6219; 13−6220; 13−6221; 14−732)(Johnson, Danielle) (Entered: 04/01/2015)
467 MOTION in Limine to Limit the Testimony of Signal's Proposed Expert Enrique Gonzalez, III by Varghese Kurisinkal Devassy. (Attachments: # 1 Notice of Submission, # 2 Declaration of Eric B. Chen)(Reference: 13−6219, 13−6220, 13−6221, 14−732)(Raptis, Stephen) (Entered: 04/01/2015)
468 MOTION to Exclude the Reports and Testimony of Proferred Expert Dr. Kevin Fox Gotham by Plaintiffs. Motion set for 5/6/2015 10:00 AM before Judge Susie Morgan. (Attachments: # 1 Memorandum in Support, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4, # 6 Exhibit 5, # 7 Exhibit 6, # 8 Exhibit 7, # 9 Notice of Submission)(Reference: 13−6218, 13−6219, 13−6220, 13−6221, 14−732)(Adams, Daniel) (Entered: 04/01/2015)
469 MOTION to Exclude the Report and Testimony of Proferred Expert Dr. Louise Shelley by Plaintiffs. Motion set for 5/6/2015 10:00 AM before Judge Susie Morgan. (Attachments: # 1 Memorandum in Support, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Notice of Submission)(Reference: 13−6218, 13−6219, 13−6220, 13−6221,

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04/01/2015
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14−732)(Adams, Daniel) (Entered: 04/01/2015)
476 Minute Entry for proceedings held before Judge Susie Morgan: Telephone Conference held on 4/1/2015. The Burnett Defendants and the Dewan Defendants have filed a Motion for Entry of Final Judgment on Signal's crossclaims. Signal does not oppose the Motion. For the reasons stated orally and on the record, the Motion is GRANTED. The David Plaintiffs and the Burnett Defendants have submitted proposed final judgments. Any objections are due by April 10, 2015. Responses to the objections are due by April 17, 2015. The David Plaintiffs requested to unseal an Order and related briefing with respect to a previously−filed motion to stay. Any objections are due by April 8, 2015. Responses are due by April 11, 2015. The Court set an in−person status conference in the EEOC Case for April 24, 2015 at 1:30 p.m. The Plaintiff Intervenors may participate by telephone. The parties discussed the 454 Motion to Compel a Meet−and−Confer filed by the Achari Plaintiffs. Because the parties met and conferred during the telephone status conference, the Motion is GRANTED. If Signal's responses do not address Plaintiffs' concerns to their satisfaction, Plaintiffs may file a motion to compel and set it for submission before the undersigned. (Reference: All Cases)(bwn) (Entered: 04/06/2015)
470 MOTION in Limine to Exclude/Limit Report and Testimony of Amy Mowl by Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Signal International, LLC. Motion set for 4/22/2015 10:00 AM before Judge Susie Morgan. (Attachments: # 1 Memorandum in Support, # 2 Exhibit A, # 3 Exhibit B, # 4 Notice of Submission)(Reference: 13−6218, 13−6219, 13−6220, 13−6221 & 14−732)(Hangartner, Erin) (Entered: 04/02/2015)
471 MOTION in Limine to Exclude/Limit Report and Testimony of Smita Narula by Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Signal International, LLC. Motion set for 4/22/2015 10:00 AM before Judge Susie Morgan. (Attachments: # 1 Memorandum in Support, # 2 Exhibit A, # 3 Exhibit B, # 4 Notice of Submission)(Reference: 13−6218, 13−6219, 13−6220, 13−6221 & 14−732)(Hangartner, Erin) (Entered: 04/02/2015)
472 MOTION in Limine to Exclude/Limit Report and Testimony of Florence Burke by Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Signal International, LLC. Motion set for 4/22/2015 10:00 AM before Judge Susie Morgan. (Attachments: # 1 Memorandum in Support, # 2 Exhibit A (Achari), # 3 Exhibit A (David), # 4 Exhibit A (Samuel), # 5 Exhibit A (Joseph), # 6 Exhibit B, # 7 Notice of Submission)(Reference: 13−6218, 13−6219, 13−6220, 13−6221 & 14−732)(Hangartner, Erin) (Entered: 04/02/2015)
473 MOTION in Limine to Exclude/Limit Report and Testimony of Clyde Payne by Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Signal International, LLC. Motion set for 4/22/2015 10:00 AM before Judge Susie Morgan. (Attachments: # 1 Memorandum in Support, # 2 Exhibit A, # 3 Exhibit B, # 4 Notice of Submission)(Reference: 13−6218, 13−6219, 13−6220, 13−6221 & 14−732)(Hangartner, Erin) (Entered: 04/02/2015)
474 MOTION in Limine to Limit the Testimony of Cyrus D. Mehta by Signal International LLC, Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc.. Motion set for 4/22/2015 09:00 AM before Judge Susie Morgan. (Attachments: # 1 Memorandum in Support, # 2 Exhibit A−PART 1, # 3 Exhibit A−PART 2, # 4 Exhibit B, # 5 Exhibit C, # 6 Notice of Submission)(Reference: 13−6218; 13−6219; 13−6220; 13−6221; 14−732)(Hangartner, Erin) (Entered: 04/02/2015)
477 RESPONSE/MEMORANDUM in Opposition filed by Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Signal International, LLC re 467 MOTION in Limine to Limit the Testimony of Signal's Proposed Expert Enrique Gonzalez, III . (Attachments: # 1 Memorandum in Support, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C)(Reference: 13−6218, 13−6219, 13−6220, 13−6221 & 14−732)(Hangartner, Erin) (Entered: 04/16/2015)
478 RESPONSE/MEMORANDUM in Opposition filed by All Plaintiffs re 472 MOTION in Limine to Exclude/Limit Report and Testimony of Florence Burke . (Attachments: # 1 Exhibit 1)(Reference: 13−6218; 13−6219; 13−6220; 13−6221; 14−732)(Colby, Eben) (Entered: 04/16/2015)

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479 RESPONSE/MEMORANDUM in Opposition filed by Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Signal International, LLC re 468 MOTION to Exclude the Reports and Testimony of Proferred Expert Dr. Kevin Fox Gotham . (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5)(Reference: 13−6218, 13−6219, 13−6220, 13−6221 & 14−732)(Hangartner, Erin) (Entered: 04/16/2015)
480 RESPONSE/MEMORANDUM in Opposition filed by All Plaintiffs re 474 MOTION in Limine to Limit the Testimony of Cyrus D. Mehta . (Reference: 13−6219, 13−6220, 13−6221, 14−732, 14−1818)(Aiello, Justin) (Entered: 04/16/2015)
481 RESPONSE/MEMORANDUM in Opposition filed by All Plaintiffs re 471 MOTION in Limine to Exclude/Limit Report and Testimony of Smita Narula . (Attachments: # 1 Exhibit, # 2 Exhibit)(Reference: 13−6218, 13−6219, 13−6220, 13−6221, 14−732)(Sprague, Ashley) (Entered: 04/16/2015)
482 RESPONSE/MEMORANDUM in Opposition filed by All Plaintiffs re 473 MOTION in Limine to Exclude/Limit Report and Testimony of Clyde Payne The Consolidated Achari Plaintiffs' Opposition to Signal's Motion in Limine to Exclude the Testimony of Clyde Payne. (Attachments: # 1 Declaration of Eric B. Chen in Support of the Consolidated Achari Plaintiffs' Opposition to Signal's Motion in Limine to Exclude the Testimony of Clyde Payne)(Reference: 13−6219, 13−6220, 13−6221, 14−732)(Raptis, Stephen) Modified on 4/17/2015 (lag). (Entered: 04/16/2015)
483 RESPONSE/MEMORANDUM in Opposition filed by Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Signal International, LLC re 466 MOTION to Exclude Testimony and Report of Proffered Expert Ronald Signorino . (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D)(Reference: 13−6218, 13−6219, 13−6220, 13−6221 & 14−732)(Hangartner, Erin) (Entered: 04/16/2015)
484 RESPONSE/MEMORANDUM in Opposition filed by Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Signal International, LLC re 469 MOTION to Exclude the Report and Testimony of Proferred Expert Dr. Louise Shelley . (Reference: 13−6218, 13−6219, 13−6220, 13−6221 & 14−732)(Hangartner, Erin) (Entered: 04/16/2015)
485 MOTION for Partial Summary Judgment on Claims for Discrimination under 42:1981 by Achari Plaintiffs. Motion set for 5/20/2015 10:00 AM before Judge Susie Morgan. (Attachments: # 1 Memorandum in Support, # 2 Statement of Contested/Uncontested Facts, # 3 Notice of Submission, # 4 Affidavit, # 5 Exhibit A, # 6 Exhibit B, # 7 Exhibit C, # 8 Exhibit D, # 9 Exhibit E, # 10 Exhibit F, # 11 Exhibit G, # 12 Exhibit H, # 13 Exhibit I, # 14 Exhibit J, # 15 Exhibit K, # 16 Exhibit L, # 17 Exhibit M, # 18 Exhibit N, # 19 Exhibit O, # 20 Exhibit P, # 21 Exhibit Q, # 22 Exhibit R, # 23 Exhibit S, # 24 Exhibit T, # 25 Exhibit U)(Reference: 13−6218)(Grimsal, A.) Modified on 4/17/2015 (lag). (Entered: 04/16/2015)
486 RESPONSE/MEMORANDUM in Opposition filed by Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Signal International, LLC re 465 MOTION to Exclude Testimony and Report of Proffered Expert Ron McAlear . (Attachments: # 1 Exhibit A)(Reference: 13−6218, 13−6219, 13−6220, 13−6221 & 14−732)(Hangartner, Erin) (Entered: 04/16/2015)
487 RESPONSE/MEMORANDUM in Opposition filed by All Plaintiffs re 470 MOTION in Limine to Exclude/Limit Report and Testimony of Amy Mowl . (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C)(Reference: 13−6218; 13−6219; 13−6220; 13−6221: 14−732)(Grimsal, A.) Modified on 4/17/2015 (lag). (Entered: 04/16/2015)
488 MOTION for Partial Summary Judgment on Signal's Liability for Certain of its Agents' Acts by Achari Plaintiffs. Motion set for 5/20/2015 10:00 AM before Judge Susie Morgan. (Attachments: # 1 Memorandum in Support, # 2 Statement of Contested/Uncontested Facts, # 3 Notice of Submission, # 4 Affidavit, # 5 Exhibit 1, # 6 Exhibit 2, # 7 Exhibit 3, # 8 Exhibit 4, # 9 Exhibit 5, # 10 Exhibit 6, # 11 Exhibit 7, # 12 Exhibit 8, # 13 Exhibit 9, # 14 Exhibit 10, # 15 Exhibit 11, # 16 Exhibit 12, # 17 Exhibit 13, # 18 Exhibit 14, # 19 Exhibit 15, # 20 Exhibit 16, # 21 Exhibit 17, # 22 Exhibit 18)(Reference: 13−6218)(Grimsal, A.) Modified on 4/17/2015 (lag). (Entered: 04/16/2015)

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04/23/2015 04/29/2015 04/30/2015
04/30/2015 04/30/2015 04/30/2015
04/30/2015 04/30/2015 04/30/2015 04/30/2015 04/30/2015 04/30/2015 04/30/2015

489 EXPARTE/CONSENT MOTION to Withdraw Danielle E. Johnson as Attorney by Radhakrishnan Nair Mangalathu Vasukuttan. (Attachments: # 1 Proposed Order)(Reference: 14−732)(Grimsal, A.) (Entered: 04/23/2015)
490 EXPARTE/CONSENT MOTION for Extension of Time to File Oppositions as to 488 MOTION for Partial Summary Judgment , 485 MOTION for Partial Summary Judgment by Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Signal International, LLC. (Attachments: # 1 Proposed Order)(Reference: 13−6218)(Hangartner, Erin) (Entered: 04/29/2015)
491 RESPONSE/MEMORANDUM in Support filed by Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Signal International, LLC re 473 MOTION in Limine to Exclude/Limit Report and Testimony of Clyde Payne . (Attachments: # 1 Exhibit 1 − Clyde Payne expert report, # 2 Exhibit 2 − Order [David − Doc. #2132])(Reference: 13−6218, 13−6219, 13−6220, 13−6221 & 14−732)(Hangartner, Erin) (Entered: 04/30/2015)
492 ORDER granting 489 Motion to Withdraw as Attorney. Attorney Danielle E. Johnson terminated. Signed by Judge Susie Morgan. (Reference: 14−732)(bwn) (Entered: 04/30/2015)
493 RESPONSE/MEMORANDUM in Support filed by Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Signal International, LLC re 474 MOTION in Limine to Limit the Testimony of Cyrus D. Mehta . (Reference: 13−6218, 13−6219, 13−6220, 13−6221 & 14−732)(Hangartner, Erin) (Entered: 04/30/2015)
494 RESPONSE/MEMORANDUM in Support filed by Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Signal International, LLC re 470 MOTION in Limine to Exclude/Limit Report and Testimony of Amy Mowl . (Attachments: # 1 Exhibit A − Depo of Amy Mowl, # 2 Exhibit B − Achari−Amy Mowl Expert Report, # 3 Exhibit C − David−Amy Mowl Expert Report)(Reference: 13−6218, 13−6219, 13−6220, 13−6221 & 14−732)(Hangartner, Erin) (Entered: 04/30/2015)
495 RESPONSE/MEMORANDUM in Support filed by Pravin Kumar Singh, Radhakrishnan Nair Mangalathu Vasukuttan re 466 MOTION to Exclude Testimony and Report of Proffered Expert Ronald Signorino . (Reference: 13−6219, 12−6220, 13−6221, 14−732)(Mehta, Mona) (Entered: 04/30/2015)
496 RESPONSE/MEMORANDUM in Support filed by Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Signal International, LLC re 471 MOTION in Limine to Exclude/Limit Report and Testimony of Smita Narula . (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C)(Reference: 13−6218, 13−6219, 13−6220, 13−6221 & 14−732)(Hangartner, Erin) (Entered: 04/30/2015)
497 REPLY to Response to Motion filed by All Plaintiffs re 468 MOTION to Exclude the Reports and Testimony of Proferred Expert Dr. Kevin Fox Gotham . (Reference: 13−6218, 13−6219, 13−6220, 13−6221, 14−732)(Colby, Eben) (Entered: 04/30/2015)
498 REPLY to Response to Motion filed by All Plaintiffs re 465 MOTION to Exclude Testimony and Report of Proffered Expert Ron McAlear . (Reference: 13−6218, 13−6219, 13−6220, 13−6221, 14−732)(Colby, Eben) (Entered: 04/30/2015)
499 REPLY to Response to Motion filed by Plaintiffs re 469 MOTION to Exclude the Report and Testimony of Proferred Expert Dr. Louise Shelley . (Reference: 13−6218; 13−6221; 13−6220; 13−6219; 14−732)(Grimsal, A.) (Entered: 04/30/2015)
500 Response/Reply by Varghese Kurisinkal Devassy Achari Plaintiffs Reply in Support of Motion in Limine to Limit the Testimony of Signal's Proposed Expert Enrique Gonzalez, III (Reference: 13−6219, 13−6220, 13−6221, 14−732)(Raptis, Stephen) (Entered: 04/30/2015)
501 Declaration by Varghese Kurisinkal Devassy Declaration of Eric B. Chen in Support of Achari Plaintiffs' Reply in Support of Motion in Limine to Limit the Testimony of Signal's Proposed Expert Enrique Gonzalez, III (Reference: 13−6219, 13−6220, 13−6221, 14−732)(Raptis, Stephen) (Entered: 04/30/2015)

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04/30/2015 05/01/2015 05/04/2015
05/04/2015
05/04/2015
05/04/2015 05/06/2015 05/08/2015 05/11/2015 05/18/2015 05/18/2015 05/18/2015

502 RESPONSE/MEMORANDUM in Support filed by Signal International LLC, Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc. re 472 MOTION in Limine to Exclude/Limit Report and Testimony of Florence Burke . (Reference: 13−6218, 13−6218, 13−6220, 13−6221, 14−732)(Hangartner, Erin) (Entered: 04/30/2015)
503 ORDER granting 490 Motion for Extension of Time to File Oppositions as to 488 MOTION for Partial Summary Judgment, 485 MOTION for Partial Summary Judgment. Signed by Judge Susie Morgan. (Reference: 13−6218)(bwn) (Entered: 05/01/2015)
504 MOTION for Summary Judgment on Signal's Cross Claims by Malvern C. Burnett, Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C., Law Offices of Malvern C. Burnett, A.P.C. Motion set for 5/20/2015 10:00 AM before Judge Susie Morgan. (Attachments: # 1 Statement of Contested/Uncontested Facts, # 2 Memorandum in Support, # 3 Proposed Order, # 4 Notice of Submission)(Reference: 14−1818)(Cerniglia, Timothy) (Entered: 05/04/2015)
505 RESPONSE/MEMORANDUM in Opposition filed by Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Signal International, LLC re 488 MOTION for Partial Summary Judgment concerning Signal's Liability for its Agents' Acts. (Attachments: # 1 Statement of Contested/Uncontested Facts, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D)(Reference: 13−6218)(Hangartner, Erin) (Entered: 05/04/2015)
506 RESPONSE/MEMORANDUM in Opposition filed by Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Signal International, LLC re 485 MOTION for Partial Summary Judgment on Claims for Discrimination under 42 U.S.C. § 1981. (Attachments: # 1 Statement of Contested/Uncontested Facts, # 2 Exhibit A, # 3 Exhibit B)(Reference: 13−6218)(Hangartner, Erin) (Entered: 05/04/2015)
507 EXPARTE/CONSENT MOTION to Join in Burnett Defendants' Motion for Summary Judgment on Signal's Cross Claims by Sachin Dewan, Dewan Consultants Pvt. Ltd. (Attachments: # 1 Proposed Order)(Reference: 14−1818)(Shapiro, Stephen) (Entered: 05/04/2015)
508 ORDER granting 507 Motion to Join in Burnett Defendants' Motion for Summary Judgment on Signal's Cross Claims. Signed by Judge Susie Morgan. (Reference: 14−1818)(bwn) (Entered: 05/06/2015)
509 EXPARTE/CONSENT Consent MOTION for Extension of Time to File Opposition to Burnett's Motion for Summary Judgment on Signal's Cross Claims by Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Signal International, LLC. (Attachments: # 1 Proposed Order)(Reference: 14−1818)(Hangartner, Erin) (Entered: 05/08/2015)
510 ORDER granting 509 Motion for Extension of Time to File Opposition to Burnett's Motion for Summary Judgment on Signal's Cross Claims. IT IS ORDERED that the deadline(s) for Signal to file its opposition(s) to Burnetts Motion(s) for Summary Judgment on Signals Cross Claims, is May 18, 2015. Signed by Judge Susie Morgan. (Reference: 14−1818)(bwn) (Entered: 05/11/2015)
511 Witness List by Signal International, Inc., Signal International, LLC. (Reference: 13−6218)(Hangartner, Erin) (Entered: 05/18/2015)
512 Exhibit List by Signal International, Inc., Signal International, LLC. (Reference: 13−6218)(Hangartner, Erin) (Entered: 05/18/2015)
513 RESPONSE/MEMORANDUM in Opposition filed by Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Signal International, LLC re 504 MOTION for Summary Judgment on Signal's Cross Claims . (Attachments: # 1 Statement of Contested/Uncontested Facts, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F, # 8 Exhibit G)(Reference: 14−1818)(Hangartner, Erin) (Entered: 05/18/2015)

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05/18/2015 05/18/2015 05/18/2015 05/18/2015 05/18/2015 05/18/2015 05/19/2015
05/19/2015 05/19/2015
05/21/2015 05/21/2015 06/01/2015 06/01/2015 06/02/2015 06/03/2015

514 Exhibit List by Malvern C. Burnett, Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C., Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C., Law Offices of Malvern C. Burnett, A.P.C.. (Reference: 13−6218)(Cerniglia, Timothy) (Entered: 05/18/2015)
515 Witness List by Malvern C. Burnett, Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C., Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C., Law Offices of Malvern C. Burnett, A.P.C.. (Reference: 13−6218)(Cerniglia, Timothy) (Entered: 05/18/2015)
516 Exhibit List by All Plaintiffs. (Reference: 13−6218)(Grimsal, A.) (Entered: 05/18/2015)
517 Witness List by All Plaintiffs. (Reference: 13−6218)(Grimsal, A.) (Entered: 05/18/2015)
518 Final Witness List by Sachin Dewan, Dewan Consultants Pvt. Ltd.. (Reference: 13−6218)(Shapiro, Stephen) (Entered: 05/18/2015)
519 Final Exhibit List by Sachin Dewan, Dewan Consultants Pvt. Ltd.. (Reference: 13−6218)(Shapiro, Stephen) (Entered: 05/18/2015)
520 EXPARTE/CONSENT MOTION for Leave to File Reply Memorandum to Signal's Opposition to Motion for Summary Judgment by Malvern C. Burnett, Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C.. (Attachments: # 1 Proposed Order, # 2 Proposed Pleading)(Reference: 14−1818)(Cerniglia, Timothy) (Entered: 05/19/2015)
521 REPLY to Response to Motion filed by All Plaintiffs re 488 MOTION for Partial Summary Judgment on Signal's Liability for Certain of Its Agents' Acts. (Attachments: # 1 Statement of Contested/Uncontested Facts)(Reference: 13−6218)(Grimsal, A.) (Entered: 05/19/2015)
522 REPLY to Response to Motion filed by All Plaintiffs re 485 MOTION for Partial Summary Judgment on Claims for Discrimination under 42 U.S.C. 1981. (Attachments: # 1 Statement of Contested/Uncontested Facts, # 2 Affidavit, # 3 Exhibit A, # 4 Exhibit B, # 5 Exhibit C, # 6 Exhibit D, # 7 Exhibit E, # 8 Exhibit F, # 9 Exhibit G, # 10 Exhibit H, # 11 Exhibit I, # 12 Exhibit J, # 13 Exhibit K, # 14 Exhibit L, # 15 Exhibit M, # 16 Exhibit N, # 17 Exhibit O, # 18 Exhibit P, # 19 Exhibit Q, # 20 Exhibit R, # 21 Exhibit S, # 22 Exhibit T)(Reference: 13−6218)(Grimsal, A.) (Entered: 05/19/2015)
523 ORDER granting 520 Motion for Leave to File Reply Memorandum to Signal's Opposition to Motion for Summary Judgment. Signed by Judge Susie Morgan. (Reference: 14−1818)(bwn) (Entered: 05/21/2015)
524 REPLY to Response to Motion filed by Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C. re 504 MOTION for Summary Judgment on Signal's Cross Claims. (Reference: 14−1818)(bwn) (Entered: 05/21/2015)
525 ORDER − IT IS ORDERED that a telephone status conference is SET in all cases for June 2, 2015, at 11:30 a.m. The Court's judicial assistant will circulate call−in instructions. Signed by Judge Susie Morgan on 5/31/2015.(Reference: All Cases)(bwn) (Entered: 06/01/2015)
526 ORDER − IT IS ORDERED that Signal identify all actions before this Court in which it has filed crossclaims by June 3, 2015. Signed by Judge Susie Morgan.(Reference: All Cases)(bwn) (Entered: 06/01/2015)
533 Minute Entry for proceedings held before Judge Susie Morgan: Telephone Conference held on 6/2/2015. (Reference: All Cases)(bwn) (Entered: 06/05/2015)
527 ***DEFICIENT*** ANSWER to 198 Amended Complaint,, with Jury Demand , CROSSCLAIM with Jury Demand against Malvern C. Burnett, Sachin Dewan, Dewan Consultants Pvt. Ltd., Global Resources Inc, Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C., Michael Pol by Signal International, LLC, Signal International, Inc..(Reference: 13−6221)(Hangartner, Erin) Modified on 6/9/2015 (bwn). (Entered: 06/03/2015)

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06/03/2015
06/03/2015
06/03/2015
06/03/2015
06/03/2015 06/04/2015 06/05/2015 06/08/2015
06/08/2015 06/09/2015
06/09/2015 06/09/2015

528 ***DEFICIENT*** ANSWER to 201 Amended Complaint, with Jury Demand , CROSSCLAIM with Jury Demand against Malvern C. Burnett, Sachin Dewan, Dewan Consultants Pvt. Ltd., Global Resources Inc, Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C., Michael Pol by Signal International, LLC.(Reference: 13−6220)(Hangartner, Erin) Modified on 6/9/2015 (bwn). (Entered: 06/03/2015)
529 ***DEFICIENT*** ANSWER to Complaint with Jury Demand , CROSSCLAIM with Jury Demand against Malvern C. Burnett, Sachin Dewan, Dewan Consultants Pvt. Ltd., Global Resources Inc, Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C., Michael Pol by Signal International, LLC, Signal International, Inc..(Reference: 14−732)(Hangartner, Erin) Modified on 6/9/2015 (bwn). (Entered: 06/03/2015)
530 ***DEFICIENT*** ANSWER to 200 Amended Complaint,,,,, with Jury Demand , CROSSCLAIM with Jury Demand against Malvern C. Burnett, Sachin Dewan, Dewan Consultants Pvt. Ltd., Global Resources Inc, Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C. by Signal International, LLC, Signal International, Inc..(Reference: 13−6218)(Hangartner, Erin) Modified on 6/9/2015 (bwn). (Entered: 06/03/2015)
531 ***DEFICIENT*** ANSWER to 199 Amended Complaint,,, with Jury Demand , CROSSCLAIM with Jury Demand against Malvern C. Burnett, Sachin Dewan, Dewan Consultants Pvt. Ltd., Global Resources Inc, Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C. by Signal International, LLC, Signal International, Inc..(Reference: 13−6219)(Hangartner, Erin) Modified on 6/9/2015 (bwn). (Entered: 06/03/2015)
532 Memorandum by Signal International, Inc., Signal International, LLC re 526 Order (Reference: 13−6218, 13−6219, 13−6220, 13−6221, 14−732 & 14−1818))(Hangartner, Erin) (Entered: 06/03/2015)
534 ORDER granting in part 333 Motion for Partial Summary Judgment; denying 485 Motion for Partial Summary Judgment; and denying 488 Motion for Partial Summary Judgment. Signed by Judge Susie Morgan on 6/4/2015. (Reference: 13−6218)(bwn) (Entered: 06/05/2015)
535 EXPARTE/CONSENT MOTION Change Trial Attorney Designation by Plaintiffs. (Attachments: # 1 Proposed Order)(Reference: 13−6218)(Grimsal, A.) (Entered: 06/05/2015)
536 MOTION to Dismiss Cross Claims of Signal International by Malvern C. Burnett, Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C., Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C.. Motion(s) will be submitted on 7/1/2015. (Attachments: # 1 Memorandum in Support, # 2 Proposed Order, # 3 Notice of Submission)(Reference: 13−6218)(Cerniglia, Timothy) (Entered: 06/08/2015)
537 ORDER granting 535 Motion to Change Trial Attorney Designation. Signed by Judge Susie Morgan. (Reference: 13−6218)(bwn) (Entered: 06/08/2015)
538 ***DEFICIENT*** CROSSCLAIM with Jury Demand against Signal International LLC, Signal International, Inc., Signal International, Inc., Signal International, LLC, Signal International, LLC filed by Gulf Coast Immigration Law Center, L.L.C., Gulf Coast Immigration Law Center, L.L.C., Malvern C. Burnett, Law Offices of Malvern C. Burnett, A.P.C., Law Offices of Malvern C. Burnett, A.P.C., Malvern C. Burnett.(Reference: 13−6218, 13−6219, 13−6220; 13−6221; 14−427, 14−1818)(Cerniglia, Timothy) Modified on 6/9/2015 (bwn). (Entered: 06/09/2015)
539 EXPARTE/CONSENT MOTION to Join in Burnett Defendant's Motion to Dismiss Signal's Cross Claims, or, alternatively for Summary Judgment by Sachin Dewan, Dewan Consultants Pvt. Ltd. (Attachments: # 1 Proposed Order)(Reference: 13−6218)(Shapiro, Stephen) (Entered: 06/09/2015)
540 ORDER DENYING AS MOOT 536 Motion to Dismiss Cross Claims of Signal International. Signed by Judge Susie Morgan. (Reference: Achari Cases)(bwn) (Entered: 06/09/2015)

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06/10/2015 06/10/2015 06/11/2015 06/11/2015 06/15/2015 06/15/2015
06/15/2015 06/15/2015 06/15/2015
06/15/2015
06/15/2015 06/15/2015 06/15/2015 06/16/2015

541 EXPARTE/CONSENT MOTION to Withdraw Mona V. Mehta as Attorney by Pravin Kumar Singh, Radhakrishnan Nair Mangalathu Vasukuttan. (Attachments: # 1 Proposed Order)(Reference: 14−732)(Grimsal, A.) (Entered: 06/10/2015)
542 Proposed Pretrial Order and Exhibits by Achari Plaintiffs, Signal Defendants, Dewan Defendants, and Burnett Defendants. (Attachments: # 1 Exhibit A − P, # 2 Exhibit Q, # 3 Exhibit R Stage 1, # 4 Exhibit R Stage 2)(Reference: 13−6218)(Grimsal, A.) Modified on 6/11/2015 to edit filers (bwn). (Entered: 06/10/2015)
543 ORDER DENYING AS MOOT 539 Motion to Join in Burnett Defendant's Motion to Dismiss Signal's Cross Claims, or, alternatively for Summary Judgment. Signed by Judge Susie Morgan on 6/11/2015. (Reference: 13−6218)(bwn) (Entered: 06/12/2015)
544 ORDER granting 541 Motion to Withdraw as Attorney. Attorney Mona Mehta terminated. Signed by Judge Susie Morgan on 6/11/2015. (Reference: 14−732)(bwn) (Entered: 06/12/2015)
545 EXPARTE/CONSENT MOTION to Continue Trial and Pretrial Deadlines by Plaintiffs. (Attachments: # 1 Exhibit Adams Declaratioh, # 2 Exhibit Donoho Declaration, # 3 Exhibit Werner Declaration, # 4 Proposed Order)(Reference: 13−6218)(Grimsal, A.) Modified on 6/16/2015 (bwn). (Entered: 06/15/2015)
546 MOTION in Limine to Exclude Inadmissible Evidence and Testimony of Plaintiffs' and Signal's Immigration Law Experts by Burnett Defendants. Motion(s) will be submitted on 7/1/2015. (Attachments: # 1 Memorandum in Support, # 2 Proposed Order, # 3 Notice of Submission)(Reference: 13−6218)Attorney Timothy W. Cerniglia added to party Malvern C. Burnett(pty:crc), Attorney Timothy W. Cerniglia added to party Law Offices of Malvern C. Burnett, A.P.C.(pty:crc).(Cerniglia, Timothy) (Entered: 06/15/2015)
547 MOTION in Limine to Exclude Evidence of Signal's Post−Lawsuit Conduct and Certain Other Irrelevant Evidence by Achari Plaintiffs. Motion(s) will be submitted on 7/1/2015. (Attachments: # 1 Memorandum in Support, # 2 Notice of Submission)(Reference: 13−6218)(Grimsal, A.) (Entered: 06/15/2015)
548 MOTION in Limine to Exclude Evidence Concerning Any Non−Retaliatory Basis for Signal's Termination of Jacob Joseph Kadakkarapally by Achari Plaintiffs. Motion(s) will be submitted on 7/1/2015. (Attachments: # 1 Memorandum in Support, # 2 Notice of Submission)(Reference: 13−6218)(Grimsal, A.) (Entered: 06/15/2015)
549 MOTION in Limine to Exclude Improper Evidence Related to Plaintiffs' or Plaintiffs' Family Members' Post−Signal Activity, and Particularly Evidence of Immigration Status, Residence, or Employment by Achari Plaintiffs. Motion(s) will be submitted on 7/1/2015. (Attachments: # 1 Memorandum in Support, # 2 Notice of Submission)(Reference: 13−6218)(Grimsal, A.) (Entered: 06/15/2015)
550 MOTION in Limine to Exclude Improper Evidence Related to Number, Political Views, or Resources of Parties' Counsel and Evidence Related to Other Cases Involving Indian Workers by Achari Plaintiffs. Motion(s) will be submitted on 7/1/2015. (Attachments: # 1 Memorandum in Support, # 2 Notice of Submission)(Reference: 13−6218)(Grimsal, A.) (Entered: 06/15/2015)
551 MOTION in Limine to Exclude Testimony, Evidence and Argument about Katrina−Related Property Damage Prior to August 2006 by Plaintiffs. Motion(s) will be submitted on 7/1/2015. (Attachments: # 1 Memorandum in Support, # 2 Exhibit, # 3 Notice of Submission)(Reference: 13−6218)(Grimsal, A.) (Entered: 06/15/2015)
552 MOTION in Limine to Exclude Testimony and Evidence by Sachin Dewan, Dewan Consultants Pvt. Ltd.. Motion(s) will be submitted on 7/1/2015. (Attachments: # 1 Memorandum in Support, # 2 Exhibit A, # 3 Proposed Order, # 4 Notice of Submission)(Reference: 13−6218)(Shapiro, Stephen) (Entered: 06/15/2015)
581 Minute Entry for proceedings held before Judge Susie Morgan: Final Pretrial Conference held on 6/15/2015. (Reference: 13−6218)(bwn) (Entered: 06/19/2015)
553 MOTION in Limine to Regarding The Use of David Verdict and Trial Testimony by Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Signal International, LLC. Motion(s) will be submitted on 7/1/2015.

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(Attachments: # 1 Memorandum in Support, # 2 Notice of Submission)(Reference: 13−6218)(Hangartner, Erin) (Entered: 06/16/2015)
554 MOTION in Limine to Exclude Unfairly Prejudicial Financial Documents From Trial by Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Signal International, LLC. Motion(s) will be submitted on 7/1/2015. (Attachments: # 1 Memorandum in Support, # 2 Exhibit A, # 3 Notice of Submission)(Reference: 13−6218)(Hangartner, Erin) (Entered: 06/16/2015)
555 MOTION in Limine to To Exclude Plaintiffs From Referring To Alleged Oral Promises As Contracts by Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Signal International, LLC. Motion(s) will be submitted on 7/1/2015. (Attachments: # 1 Memorandum in Support, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Notice of Submission)(Reference: 13−6218)(Hangartner, Erin) (Entered: 06/16/2015)
556 EXPARTE/CONSENT Consent MOTION to File Under Seal Motion in Limine Regarding the Use of Inflammatory Terms, Memorandum in Support and Exhibits by Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Signal International, LLC. (Attachments: # 1 Proposed Order)(Reference: 13−6218)(Hangartner, Erin) (Additional attachment(s) added on 6/16/2015: # 2 Proposed Pleading, # 3 Proposed Memorandum, # 4 Proposed Exhibit A, # 5 Sealed Exhibit B) (bwn). Modified on 6/16/2015 (bwn). (Entered: 06/16/2015)
557 MOTION in Limine to Authorizing Cross−Examination of Plaintiffs on Post−Signal Lives by Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Signal International, LLC. Motion(s) will be submitted on 7/1/2015. (Attachments: # 1 Memorandum in Support, # 2 Exhibit A, # 3 Exhibit B, # 4 Notice of Submission)(Reference: 13−6218)(Hangartner, Erin) (Entered: 06/16/2015)
558 MOTION in Limine to Exclude Evidence Related to OSHA Applicability and Compliance by Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Signal International, LLC. Motion(s) will be submitted on 7/1/2015. (Attachments: # 1 Memorandum in Support, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Notice of Submission)(Reference: 13−6218)(Hangartner, Erin) (Entered: 06/16/2015)
559 MOTION in Limine to Exclude Certain Types of Legal Coercion Evidence by Signal International, Inc., Signal International, LLC. Motion(s) will be submitted on 7/1/2015. (Attachments: # 1 Memorandum in Support, # 2 Notice of Submission)(Reference: 13−6218)(Hangartner, Erin) (Entered: 06/16/2015)
560 MOTION in Limine to Exclude Evidence Related to Gender Base Equal Pay Act Lawsuit by Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Signal International, LLC. Motion(s) will be submitted on 7/1/2015. (Attachments: # 1 Memorandum in Support, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Notice of Submission)(Reference: 13−6218)(Hangartner, Erin) (Entered: 06/16/2015)
561 ***DEFICIENT*** MOTION for Leave to File Answer, Affirmative Defenses and Cross Claims to Plaintiffs' Second Amended Complaint by Signal International, Inc., Signal International, LLC. (Attachments: # 1 Memorandum in Support, # 2 Proposed Order, # 3 Proposed Pleading (Answer, Affirmative Defenses and Cross Claims of Signal to Plaintiffs' Second Amended Complaint))(Reference: 13−6218)(Hangartner, Erin) Modified on 6/17/2015 (bwn). (Entered: 06/16/2015)
562 ***DEFICIENT*** MOTION for Leave to File Answer, Affirmative Defenses and Cross Claims to Plaintiffs' First Amended Complaint by Signal International, Inc., Signal International, LLC. (Attachments: # 1 Memorandum in Support, # 2 Proposed Order, # 3 Proposed Pleading Answer, Affirmative Defenses and Cross Claims to Plaintiffs' First Amended Complaint)(Reference: 13−6219)(Hangartner, Erin) Modified on 6/17/2015 (bwn). (Entered: 06/16/2015)
563 ***DEFICIENT*** MOTION for Leave to File Answer, Affirmative Defenses and Cross Claims to Plaintiffs' First Amended Complaint by Signal International, LLC. (Attachments: # 1 Memorandum in Support, # 2 Proposed Order, # 3 Proposed

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Pleading (Answer, Affirmative Defenses and Cross Claims of Signal to Plaintiffs' First Amended Complaint))(Reference: 13−6220)(Hangartner, Erin) Modified on 6/17/2015 (bwn). (Entered: 06/16/2015)
564 ***DEFICIENT*** MOTION for Leave to File Answer, Affirmative Defenses and Cross Claims to Plaintiffs' First Amended Complaint by Signal International, Inc., Signal International, LLC. (Attachments: # 1 Memorandum in Support, # 2 Proposed Order, # 3 Proposed Pleading (Answer, Affirmative Defenses and Cross Claims of Signal to Plaintiffs' First Amended Complaint))(Reference: 13−6221)(Hangartner, Erin) Modified on 6/17/2015 (bwn). (Entered: 06/16/2015)
565 ***DEFICIENT*** MOTION for Leave to File Answer, Affirmative Defenses and Cross Claims to Plaintiffs' First Amended Complaint by Signal International, Inc., Signal International, LLC. (Attachments: # 1 Memorandum in Support, # 2 Proposed Order, # 3 Proposed Pleading (Answer, Affirmative Defenses and Cross Claims of Signal to Plaintiffs' First Amended Complaint))(Reference: 14−732)(Hangartner, Erin) Modified on 6/17/2015 (bwn). (Entered: 06/16/2015)
566 EXPARTE/CONSENT MOTION for Leave to File Under Seal Motion in Limine to Exclude Unfairly Prejudicial Video Clips of Ronald Schnoor From Trial by Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Signal International, LLC. (Attachments: # 1 Proposed Order)(Reference: 13−6218)(Hangartner, Erin) (Additional attachment(s) added on 6/17/2015: # 2 Proposed Motion in Limine, # 3 Proposed Memorandum, # 4 Proposed Exhibit A, # 5 Proposed Notice of Submission) (bwn). (Entered: 06/16/2015)
567 Request/Statement of Oral Argument by Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Signal International, LLC regarding 553 MOTION in Limine to Regarding The Use of David Verdict and Trial Testimony (Reference: 13−6218)(Hangartner, Erin) (Entered: 06/16/2015)
568 RESPONSE/MEMORANDUM in Opposition filed by Malvern C. Burnett, Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C., Law Offices of Malvern C. Burnett, A.P.C. re 561 MOTION for Leave to File Answer, Affirmative Defenses and Cross Claims to Plaintiffs' Second Amended Complaint . (Reference: 13−6218)(Cerniglia, Timothy) (Entered: 06/16/2015)
569 MOTION for Leave to File Cross Claims against Signal by Malvern C. Burnett, Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C., Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C., Law Offices of Malvern C. Burnett, A.P.C.. Motion(s) will be submitted on 7/1/2015. (Attachments: # 1 Proposed Pleading Cross Claim against signal, # 2 Proposed Order, # 3 Notice of Submission)(Reference: 13−6218, 12−6219, 13−6220, 13−6221; 14−732)(Cerniglia, Timothy) (Entered: 06/16/2015)
570 ORDER DENYING WITHOUT PREJUDICE 556 Motion for Leave to File Under Seal Motion in Limine Regarding the Use of Inflammatory Terms, Memorandum in Support and Exhibits and 566 Motion for Leave to File Under Seal Motion in Limine to Exclude Unfairly Prejudicial Video Clips of Ronald Schnoor From Trial. Signed by Judge Susie Morgan. (Reference: 13−6218)(bwn) (Entered: 06/17/2015)
571 Assertion of Contracts Breached by All Plaintiffs (Reference: 13−6218)(Grimsal, A.) (Entered: 06/17/2015)
572 MOTION for Leave to File Answer, Affirmative Defenses and Cross Claims to Plaintiffs' Second Amended Complaint by Signal International, Inc., Signal International, LLC. Motion(s) will be submitted on 7/15/2015. (Attachments: # 1 Memorandum in Support, # 2 Proposed Pleading, # 3 Notice of Submission)(Reference: 13−6218)(Hangartner, Erin) (Entered: 06/17/2015)
573 MOTION for Leave to File Answer, Affirmative Defenses and Cross Claims to Plaintiffs' First Amended Complaint by Signal International, Inc., Signal International, LLC. Motion(s) will be submitted on 7/15/2015. (Attachments: # 1 Memorandum in Support, # 2 Proposed Pleading, # 3 Notice of Submission)(Reference: 13−6219)(Hangartner, Erin) (Entered: 06/17/2015)

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06/17/2015 06/17/2015 06/17/2015 06/18/2015 06/18/2015 06/18/2015
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06/19/2015 06/19/2015 06/19/2015 06/22/2015 06/22/2015

574 MOTION for Leave to File Answer, Affirmative Defenses and Cross Claims to Plaintiffs' First Amended Complaint by Signal International, LLC. Motion(s) will be submitted on 7/15/2015. (Attachments: # 1 Memorandum in Support, # 2 Proposed Pleading, # 3 Notice of Submission)(Reference: 13−6220)(Hangartner, Erin) (Entered: 06/17/2015)
575 MOTION for Leave to File Answer, Affirmative Defenses and Cross Claims to Plaintiffs' First Amended Complaint by Signal International, Inc., Signal International, LLC. Motion(s) will be submitted on 7/15/2015. (Attachments: # 1 Memorandum in Support, # 2 Proposed Pleading, # 3 Notice of Submission)(Reference: 13−6221)(Hangartner, Erin) (Entered: 06/17/2015)
576 MOTION for Leave to File Answer, Affirmative Defenses and Cross Claims to Plaintiffs' First Amended Complaint by Signal International, Inc., Signal International, LLC. Motion(s) will be submitted on 7/15/2015. (Attachments: # 1 Memorandum in Support, # 2 Proposed Pleading, # 3 Notice of Submission)(Reference: 14−732)(Hangartner, Erin) (Entered: 06/17/2015)
577 ORDER DENYING 567 Request/Statement of Oral Argument, filed by Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Signal International, LLC. Signed by Judge Susie Morgan.(Reference: 13−6218)(bwn) (Entered: 06/18/2015)
578 ***FILED IN ERROR − See 279 for corrected filing*** EXPARTE/CONSENT Consent MOTION for Leave to File Under Seal Signal's Motion in Limine to Exclude Unfairly Prejudicial Video Clips of Ronald Schnoor From Trial by Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Signal International, LLC. (Attachments: # 1 Proposed Order)(Reference: 13−6218)(Hangartner, Erin) Modified on 6/19/2015 (bwn). (Entered: 06/18/2015)
579 EXPARTE/CONSENT Consent MOTION for Leave to File Under Seal Motion in Limine Regarding The Use of Inflammatory Terms by Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Signal International, LLC. (Attachments: # 1 Proposed Order)(Reference: 13−6218)(Hangartner, Erin) (Additional attachment(s) added on 6/19/2015: # 2 Proposed Motion, # 3 Proposed Memorandum, # 4 Proposed Exhibit A, # 5 Proposed Exhibit B, # 6 Proposed Notice of Submission) (bwn). (Entered: 06/18/2015)
580 EXPARTE/CONSENT Consent MOTION for Leave to File Under Seal Signal's Motion in Limine to Exclude Unfairly Prejudicial Video Clips of Ronald Schnoor From Trial by Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Signal International, LLC. (Attachments: # 1 Proposed Order)(Reference: 13−6218)(Hangartner, Erin) (Additional attachment(s) added on 6/19/2015: # 2 Proposed Motion, # 3 Proposed Memorandum, # 4 Proposed Exhibit A, # 5 Proposed Notice of Submission) (bwn). (Entered: 06/18/2015)
582 EXPARTE/CONSENT MOTION to Appear Pro Hac Vice for Rebekah Soule (Filing fee $ 100 receipt number 053L−4905948) by Plaintiffs. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Proposed Order)(Reference: 13−6218)(Grimsal, A.) (Entered: 06/19/2015)
583 EXPARTE/CONSENT MOTION to Appear Pro Hac Vice for Andrew Lugerner (Filing fee $ 100 receipt number 053L−4905962) by Plaintiffs. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Proposed Order)(Reference: 13−6218)(Grimsal, A.) (Entered: 06/19/2015)
584 EXPARTE/CONSENT MOTION to Appear Pro Hac Vice for Eric Broad (Filing fee $ 100 receipt number 053L−4905982) by Plaintiffs. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Proposed Order)(Reference: 13−6218)(Grimsal, A.) (Entered: 06/19/2015)
585 RESPONSE/MEMORANDUM in Opposition filed by All Plaintiffs re 554 MOTION in Limine to Exclude Unfairly Prejudicial Financial Documents From Trial . (Reference: 13−6218)(Grimsal, A.) (Entered: 06/22/2015)
586 RESPONSE/MEMORANDUM in Opposition filed by All Plaintiffs re 558 MOTION in Limine to Exclude Evidence Related to OSHA Applicability and Compliance . (Attachments: # 1 Exhibit)(Reference: 13−6218)(Grimsal, A.) (Entered: 06/22/2015)

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06/22/2015 06/22/2015 06/22/2015 06/22/2015 06/22/2015 06/22/2015 06/22/2015
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06/22/2015

587 ORDER granting 579 Motion for Leave to File Under Seal Motion in Limine Regarding The Use of Inflammatory Terms. Signed by Judge Susie Morgan on 6/22/2015. (Reference: 13−6218)(bwn) (Entered: 06/22/2015)
588 MOTION in Limine Regarding the Use of Inflammatory Terms by Signal Defendants. (Attachments: # 1 Memorandum in Support, # 2 Exhibit A, # 3 Exhibit B, # 4 Notice of Submission) (Reference: 13−6218)(bwn) (Entered: 06/22/2015)
589 ORDER granting 580 Motion for Leave to File Under Seal Signal's Motion in Limine to Exclude Unfairly Prejudicial Video Clips of Ronald Schnoor From Trial. Signed by Judge Susie Morgan. (Reference: 13−6218)(bwn) (Entered: 06/22/2015)
590 MOTION in Limine to Exclude Unfairly Prejudicial Video Clips of Ronald Schnoor From Trial by Signal Defendants. (Attachments: # 1 Memorandum in Support, # 2 Exhibit A, # 3 Notice of Submission) (Reference: 13−6218)(bwn) (Entered: 06/22/2015)
591 RESPONSE/MEMORANDUM in Opposition filed by All Plaintiffs re 557 MOTION in Limine to Authorizing Cross−Examination of Plaintiffs on Post−Signal Lives . (Reference: 13−6218)(Grimsal, A.) (Entered: 06/22/2015)
592 RESPONSE/MEMORANDUM in Opposition filed by All Plaintiffs re 560 MOTION in Limine to Exclude Evidence Related to Gender Base Equal Pay Act Lawsuit of Lisa Spears. (Attachments: # 1 Exhibit)(Reference: 13−6218)(Grimsal, A.) (Entered: 06/22/2015)
593 RESPONSE/MEMORANDUM in Opposition filed by Signal International, Inc., Signal International, LLC re 546 MOTION in Limine to Exclude Inadmissible Evidence and Testimony of Plaintiffs' and Signal's Immigration Law Experts . (Attachments: # 1 Exhibit A − Order [Doc. 2136], # 2 Exhibit B − Expert Report of Enrique Gonzalez)(Reference: 13−6218)(Hangartner, Erin) (Entered: 06/22/2015)
594 RESPONSE/MEMORANDUM in Opposition filed by Signal International, Inc., Signal International, LLC re 552 MOTION in Limine to Exclude Testimony and Evidence . (Reference: 13−6218)(Hangartner, Erin) (Entered: 06/22/2015)
595 RESPONSE/MEMORANDUM in Opposition filed by All Plaintiffs re 555 MOTION in Limine to To Exclude Plaintiffs From Referring To Alleged Oral Promises As Contracts . (Reference: 13−6218)(Grimsal, A.) (Entered: 06/22/2015)
596 RESPONSE/MEMORANDUM in Opposition filed by Signal International, Inc., Signal International, LLC re 551 MOTION in Limine to Exclude Testimony, Evidence and Argument about Katrina−Related Property Damage Prior to August 2006 . (Attachments: # 1 Exhibit A − Depo of Kevin Fox Gotham, # 2 Exhibit B − Feb. 27 − Mar. 1, 2006 email exchange, # 3 Exhibit C − Oct. 28, 2005 email exchange, # 4 Exhibit D − Oct. 6, 2005 email)(Reference: 13−6218)(Hangartner, Erin) (Entered: 06/22/2015)
597 RESPONSE/MEMORANDUM in Opposition filed by All Plaintiffs re 553 MOTION in Limine to Regarding The Use of David Verdict and Trial Testimony . (Attachments: # 1 Exhibit A, # 2 Exhibit B−1, # 3 Exhibit B−2, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E)(Reference: 13−6218)(Grimsal, A.) (Entered: 06/22/2015)
598 RESPONSE/MEMORANDUM in Opposition filed by All Plaintiffs re 559 MOTION in Limine to Exclude Certain Types of Legal Coercion Evidence . (Attachments: # 1 Exhibit A, # 2 Exhibit B)(Reference: 13−6218)(Grimsal, A.) (Entered: 06/22/2015)
599 RESPONSE/MEMORANDUM in Opposition filed by Signal International, Inc., Signal International, LLC re 547 MOTION in Limine to Exclude Evidence of Signal's Post−Lawsuit Conduct and Certain Other Irrelevant Evidence . (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E)(Reference: 13−6218)(Hangartner, Erin) (Entered: 06/22/2015)
600 Memorandum Concerning Unavailable Trial Witnesses by Signal International, Inc., Signal International, LLC re 581 Pretrial Conference. (Reference: 13−6218)(Hangartner, Erin) (Entered: 06/22/2015)

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06/22/2015
06/22/2015 06/22/2015 06/22/2015 06/22/2015 06/22/2015 06/22/2015 06/24/2015 06/24/2015

601 RESPONSE/MEMORANDUM in Opposition filed by All Plaintiffs re 546 MOTION in Limine to Exclude Inadmissible Evidence and Testimony of Plaintiffs' and Signal's Immigration Law Experts . (Attachments: # 1 Exhibit)(Reference: 13−6218)(Grimsal, A.) (Entered: 06/22/2015)
602 EXPARTE/CONSENT Consent MOTION for Leave to File Under Seal Memorandum in Opposition to Plaintiffs' Motion in Limine to Exclude Evidence of Plaintiffs' or Plaintiffs' Family Members' Post−Signal Activities by Signal International, Inc., Signal International, LLC. (Attachments: # 1 Proposed Order)(Reference: 13−6218)(Hangartner, Erin) (Additional attachment(s) added on 6/23/2015: # 2 Proposed Pleading, # 3 Proposed Exhibit A, # 4 Proposed Exhibit B, # 5 Proposed Exhibit C, # 6 Proposed Exhibit D) (bwn). (Entered: 06/22/2015)
603 Statement of Witness Unavailability by Malvern C. Burnett, Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C., Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C., Law Offices of Malvern C. Burnett, A.P.C. (Reference: 13−6218)(Cerniglia, Timothy) (Entered: 06/22/2015)
604 RESPONSE/MEMORANDUM in Opposition filed by Signal International, Inc., Signal International, LLC re 550 MOTION in Limine to Exclude Improper Evidence Related to Number, Political Views, or Resources of Parties' Counsel and Evidence Related to Other Cases Involving Indian Workers . (Attachments: # 1 Exhibit A − Expert Report of Dr. Louise Shelley)(Reference: 13−6218)(Hangartner, Erin) (Entered: 06/22/2015)
605 Memorandum in Support of Allowing Unavailable Witnesses to Testify VIA Deposition at Trial in Lieu of Live Testimony by All Plaintiffs re 581 Pretrial Conference. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K, # 12 Exhibit L, # 13 Exhibit M, # 14 Exhibit N)(Reference: 13−6218)(Grimsal, A.) (Entered: 06/22/2015)
606 Proposed Pretrial Order by All Plaintiffs, Signal Defendants, Dewan Defendants, and Burnett Defendants. (Attachments: # 1 Exhibit A − P, # 2 Exhibit Q (Jury Instructions), # 3 Exhibit R Stage 1 (Verdict form), # 4 Exhibit R Stage 2 (Verdict form))(Reference: 13−6218)(Grimsal, A.) Modified on 6/23/2015 to edit filers. (bwn). (Entered: 06/22/2015)
607 RESPONSE/MEMORANDUM in Opposition filed by Signal International, Inc., Signal International, LLC re 548 MOTION in Limine to Exclude Evidence Concerning Any Non−Retaliatory Basis for Signal's Termination of Jacob Joseph Kadakkarapally . (Reference: 13−6218)(Hangartner, Erin) (Entered: 06/22/2015)
608 ORDER − IT IS ORDERED that the scheduling order is AMENDED as follows: all deadlines of June 31, 2015 are RESET for June 30, 2015. Signed by Judge Susie Morgan on 6/22/2015.(Reference: 13−6218)(bwn) (Entered: 06/23/2015)
609 ORDER granting 582 Motion to Appear Pro Hac Vice as to Rebekah L. Soule. Signed by Judge Susie Morgan on 6/22/2015. (Reference: 13−6218)(bwn) (Entered: 06/23/2015)
610 ORDER granting 583 Motion to Appear Pro Hac Vice as to Andrew Richard Lugerner. Signed by Judge Susie Morgan on 6/22/2015. (Reference: 13−6218)(bwn) (Entered: 06/23/2015)
611 ORDER granting 584 Motion to Appear Pro Hac Vice as to Eric Marshall Broad. Signed by Judge Susie Morgan on 6/22/2015. (Reference: 13−6218)(bwn) (Entered: 06/23/2015)
612 ORDER granting 602 Motion for Leave to File Under Seal Memorandum in Opposition to Plaintiffs' Motion in Limine to Exclude Evidence of Plaintiffs' or Plaintiffs' Family Members' Post−Signal Activities. Signed by Judge Susie Morgan. (Reference: 13−6218)(bwn) (Entered: 06/24/2015)
613 RESPONSE/MEMORANDUM in Opposition filed by Signal Defendants re 549 MOTION in Limine to Exclude Improper Evidence Related to Plaintiffs' or Plaintiffs' Family Members' Post−Signal Activity, and Particularly Evidence of Immigration Status, Residence, or Employment. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3

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06/24/2015
06/26/2015 06/26/2015 06/26/2015 06/26/2015 06/28/2015
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Exhibit C, # 4 Exhibit D) (Reference: 13−6218)(bwn) (Entered: 06/24/2015)
614 EXPARTE/CONSENT MOTION to Join in the Burnett Defendant's Opposition to Signal's Motion for Leave to File Amended Complaints with Affirmative Defenses and Cross Claims by Sachin Dewan, Dewan Consultants Pvt. Ltd.. (Attachments: # 1 Proposed Order)(Reference: 13−6218)(Shapiro, Stephen) (Entered: 06/24/2015)
615 Proposed Voir Dire by All Plaintiffs. (Reference: 13−6218)(Grimsal, A.) (Entered: 06/26/2015)
616 OBJECTIONS by All Plaintiffs to Burnett Defendants Deposition Designations (Attachments: # 1 Exhibit)(Reference: 13−6218)(Grimsal, A.) (Entered: 06/26/2015)
617 Proposed Voir Dire by Sachin Dewan, Dewan Consultants Pvt. Ltd.. (Reference: 13−6218)(Shapiro, Stephen) (Entered: 06/26/2015)
618 OBJECTIONS by All Plaintiffs to Defendants' Proposed Exhibits (Reference: 13−6218)(Grimsal, A.) (Entered: 06/26/2015)
619 ORDER granting 553 Motion in Limine to the extent that the jury verdict in the David trial will not be the subject of trial testimony and will not be admitted into evidence in the Achari trial. Introduction of the David verdict carries the risk of undue prejudice to Signal and confusion to the jury which is not outweighed by the probative value of the jury's verdict. Signed by Judge Susie Morgan. (Reference: 13−6218)(cbn) (Entered: 06/28/2015)
620 ORDER granting 465 Motion to Exclude for the reasons stated in the David Case (08−1220, R. Doc #2069). Signed by Judge Susie Morgan. (Reference: 13−6218)(cbn) (Entered: 06/28/2015)
621 ORDER granting in part and denying in part 467 474 Motions in Limine for the reasons stated in the David case (08−1220, R.Doc #2136). Signed by Judge Susie Morgan. (Reference: 03−6218)(cbn) (Entered: 06/28/2015)
622 ORDER granting in part 470 471 Motions in Limine as set forth in order. Plaintiffs are to inform defendants of which expert they intend to have testify by 7/2/15 at 5:00 PM. Signed by Judge Susie Morgan. (Reference: 03−6218)(cbn) (Entered: 06/28/2015)
623 ORDER granting 466 ; 473 Motion to Exclude. Payne and Signorino are excluded. Signed by Judge Susie Morgan. (Reference: 03−6218)(cbn) (Entered: 06/28/2015)
624 ORDER denying 468 Motion to Exclude. Signed by Judge Susie Morgan. (Reference: 03−6218)(cbn) (Entered: 06/28/2015)
625 ORDER granting 469 472 Motions to Exclude. Shelly and Burke are excluded. Signed by Judge Susie Morgan. (Reference: 03−6218)(cbn) (Entered: 06/28/2015)
626 ORDER granting in part and denying in part 588 Motion in Limine as set forth in the sealed order in the David case (08−1220, R.Doc 2117). Signed by Judge Susie Morgan. (Reference: 03−6218)(cbn) (Entered: 06/28/2015)
627 ORDER denying 590 Motion in Limine. Signed by Judge Susie Morgan. (Reference: 03−6218)(cbn) (Entered: 06/28/2015)
628 ORDER denying 560 Motion in Limine for the reasons set forth in the David case. (08−1220, R.Doc 2097). Signed by Judge Susie Morgan. (Reference: 03−6218)(cbn) (Entered: 06/28/2015)
629 ORDER denying 554 Motion in Limine for the reasons set forth in the David case (08−1220, R.Doc #2125). Signed by Judge Susie Morgan. (Reference: 13−6218)(cbn) (Entered: 06/28/2015)
630 ORDER granting 550 Motion in Limine for the reasons set forth in the David case. (08−1220, R.Doc #2074). Signed by Judge Susie Morgan. (Reference: 13−6218)(cbn) (Entered: 06/28/2015)
631 ORDER granting 614 Motion to Join the Burnett Defendants Opposition to Signal's Motion for Leave to File Amended Answers with Affirmative Defenses and Cross Claims against Burnett. Signed by Judge Susie Morgan on 6/29/2015. (Reference: All

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06/29/2015
06/29/2015 06/29/2015 06/30/2015 06/30/2015 06/30/2015 06/30/2015 07/01/2015 07/01/2015
07/01/2015 07/01/2015

Cases)(mmm) (Entered: 06/29/2015)
632 TRANSCRIPT of Telephone Status Conference held on June 2, 2015 before Judge Susie Morgan. Court Reporter/Recorder Terri Hourigan, Telephone number 504−589−7775. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Recorder before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Parties have 21 days from the filing of this transcript to file with the Court a Redaction Request. Release of Transcript Restriction set for 9/28/2015. (Reference: All Cases)(rsg) (Entered: 06/29/2015)
633 Minute Entry for proceedings held before Judge Susie Morgan: Status Conference held on 6/29/2015. Parties updated the Court on settlement negotiations. Status conference set 6/30/15 is reset for 7/1/15 at 11:30 a.m. Trial counsel in the Achari case shall attend in person. Counsel in the related cases may (but need not) participate via telephone. Court will circulate a call−in number. (Reference: 13−6218)(cbn) (Entered: 06/29/2015)
634 ORDER granting in part and denying in part 551 Motion in Limine as set forth in the David Case. Signed by Judge Susie Morgan. (Reference: 1306218)(cbn) (Entered: 06/29/2015)
635 List of Demonstrative Exhibits for Opening Statement by All Plaintiffs . (Reference: 13−6218)(Grimsal, A.) (Entered: 06/30/2015)
636 EXPARTE/CONSENT MOTION to Withdraw Aaron M. Safane as Attorney by Plaintiffs. (Attachments: # 1 Proposed Order)(Reference: 13−6218)(Grimsal, A.) (Entered: 06/30/2015)
637 TRIAL Memorandum by Malvern C. Burnett, Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C., Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C., Law Offices of Malvern C. Burnett, A.P.C. Of Demonstrative Exhibits for use during opening statement. (Reference: 13−6218)(Cerniglia, Timothy) Modified text on 7/1/2015 (sek). (Entered: 06/30/2015)
638 Response/Reply by Malvern C. Burnett, Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C., Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C., Law Offices of Malvern C. Burnett, A.P.C. To Plaintiffs' Objection to Deposition Designation of Manish Dewan (Attachments: # 1 Exhibit)(Reference: 13−6213)(Cerniglia, Timothy) Modified text on 7/1/2015 (sek). (Entered: 06/30/2015)
639 OBJECTIONS by All Plaintiffs re 637 Memorandum, by Malvern C. Burnett's Proposed Demonstrative Exhibits for Use During Opening Statement (Reference: 13−6218)(Grimsal, A.) (Entered: 07/01/2015)
640 Minute Order. Proceedings held before Judge Susie Morgan: Status Conference held on 7/1/2015. Plaintiffs orally moved for a continuance of the Achari trial. Defendants did not object. For the reasons stated orally and on the record, the motion is GRANTED, and trial is CONTINUED to July 20, 2015. All pre−trial deadlines shall remain unchanged. The parties discussed the motions for leave to file crossclaims in the consolidated Achari cases. Defendants do not oppose each other's motions. Accordingly, the Motions are GRANTED. By consent of the parties, Defendants may file crossclaims in the consolidated Achari cases and the Texas cases by July 8, 2015. A follow−up status conference is SET for July 14, 2015 at 10:00 a.m. (Reference: 13−6218)(bwn) (Entered: 07/02/2015)
641 CROSSCLAIM with Jury Demand against Signal International LLC, Signal International, Inc. filed by Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C., Malvern C. Burnett.(Reference: 13−6218, 13−6220, 13−6221, 14−732)(bwn) (Entered: 07/02/2015)
642 CROSSCLAIM with Jury Demand against Malvern C. Burnett, Sachin Dewan, Dewan Consultants Pvt. Ltd., Global Resources Inc, Law Offices of Malvern C. Burnett, A.P.C., Gulf Coast Immigration Law Center, L.L.C. filed by Signal International, LLC, Signal International, Inc.(Reference: 13−6218)(bwn) (Entered: 07/02/2015)

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07/01/2015
07/01/2015 07/01/2015 07/01/2015 07/02/2015
07/02/2015 07/02/2015 07/02/2015 07/02/2015 07/02/2015 07/02/2015 07/02/2015 07/03/2015

643 CROSSCLAIM with Jury Demand against Malvern C. Burnett, Sachin Dewan, Dewan Consultants Pvt. Ltd., Global Resources Inc, Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C. filed by Signal International, LLC, Signal International, Inc., Signal International Texas, L.P.(Reference: 13−6219)(bwn) (Entered: 07/02/2015)
644 CROSSCLAIM with Jury Demand against Malvern C. Burnett, Sachin Dewan, Dewan Consultants Pvt. Ltd., Global Resources Inc, Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C. filed by Signal International, Inc., Signal International, LLC.(Reference: 13−6220)(bwn) (Entered: 07/02/2015)
645 CROSSCLAIM with Jury Demand against Malvern C. Burnett, Sachin Dewan, Dewan Consultants Pvt. Ltd., Global Resources Inc, Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C. filed by Signal International, Inc., Signal International, LLC.(Reference: 13−6221)(bwn) (Entered: 07/02/2015)
646 CROSSCLAIM with Jury Demand against Malvern C. Burnett, Sachin Dewan, Dewan Consultants Pvt. Ltd., Global Resources Inc, Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C. filed by Signal International, Inc., Signal International, LLC.(Reference: 14−732)(bwn) (Entered: 07/02/2015)
647 Minute Entry for proceedings held before Magistrate Judge Daniel E. Knowles, III: Settlement Conference held on 7/2/2015. Settlement can not be reached at this time. Telephone Conference set for 7/15/2015 03:30 PM before Magistrate Judge Daniel E. Knowles III. Counsel for Achari shall set up a dial in phone number and provide it to everyone. Defendants, Burnett and Dewan have agreed, without waiving any defenses to such a request, to voluntarily provide financial statements to the Court for in−camera review. These documents will be provided no later than the close of business on Thursday, July 9, 2015. (Reference: 13−6218)(plh) (Entered: 07/02/2015)
648 ORDER granting 636 Motion to Withdraw as Attorney. Attorney Aaron M. Safane terminated. Signed by Judge Susie Morgan. (Reference: 13−6218)(bwn) (Entered: 07/02/2015)
649 EXPARTE/CONSENT MOTION for Leave to File Cross Claims Against Signal by Sachin Dewan, Dewan Consultants Pvt. Ltd. (Attachments: # 1 Proposed Pleading, # 2 Proposed Order)(Reference: 13−6218)(Shapiro, Stephen) (Entered: 07/02/2015)
650 EXPARTE/CONSENT MOTION for Leave to File Cross Claims Against Signal by Sachin Dewan, Dewan Consultants Pvt. Ltd.. (Attachments: # 1 Proposed Pleading, # 2 Proposed Order)(Reference: 13−6219)(Shapiro, Stephen) (Entered: 07/02/2015)
651 EXPARTE/CONSENT MOTION for Leave to File Cross Claims Against Signal by Sachin Dewan, Dewan Consultants Pvt. Ltd.. (Attachments: # 1 Proposed Pleading, # 2 Proposed Order)(Reference: 13−6220)(Shapiro, Stephen) (Entered: 07/02/2015)
652 EXPARTE/CONSENT MOTION for Leave to File Cross Claims Against Signal by Sachin Dewan, Dewan Consultants Pvt. Ltd.. (Attachments: # 1 Proposed Pleading, # 2 Proposed Order)(Reference: 13−6221)(Shapiro, Stephen) (Entered: 07/02/2015)
653 EXPARTE/CONSENT MOTION for Leave to File Cross Claims Against Signal by Sachin Dewan, Dewan Consultants Pvt. Ltd.. (Attachments: # 1 Proposed Pleading, # 2 Proposed Order)(Reference: 14−732)(Shapiro, Stephen) (Entered: 07/02/2015)
654 EXPARTE/CONSENT MOTION for Leave to File Cross Claims Against Signal by Sachin Dewan, Dewan Consultants Pvt. Ltd.. (Attachments: # 1 Proposed Pleading, # 2 Proposed Order)(Reference: 14−1818)(Shapiro, Stephen) (Entered: 07/02/2015)
655 CROSSCLAIM with Jury Demand against Signal International, Inc., Signal International, Inc.((13−6219, 13−6221, 14−732, 14−1818)), Signal International, LLC, Signal International, LLC filed by Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C., Law Offices of Malvern C. Burnett, A.P.C., Malvern C. Burnett, Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C..(Reference: 13−6219)Attorney Timothy W. Cerniglia added to party Gulf Coast Immigration Law Center, L.L.C.(pty:crd).(Cerniglia, Timothy) (Entered: 07/03/2015)

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 239 of 250

07/03/2015
07/03/2015
07/03/2015 07/03/2015 07/03/2015 07/03/2015 07/03/2015 07/03/2015 07/03/2015 07/03/2015 07/06/2015 07/06/2015 07/06/2015

656 CROSSCLAIM with Jury Demand against Signal International LLC((13−6220)), Signal International, Inc., Signal International, Inc.((13−6219, 13−6221, 14−732, 14−1818)), Signal International, LLC, Signal International, LLC((13−6219, 13−6221, 14−732, 14−1818)) filed by Law Offices of Malvern C. Burnett, A.P.C.((13−6219, 13−6220, 13−6221, 14−732, 14−1818)), Gulf Coast Immigration Law Center, L.L.C., Malvern C. Burnett, Law Offices of Malvern C. Burnett, A.P.C., Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C..(Reference: 13−6220)(Cerniglia, Timothy) (Entered: 07/03/2015)
657 CROSSCLAIM with Jury Demand against Signal International LLC((13−6220)), Signal International, Inc., Signal International, Inc.((13−6219, 13−6221, 14−732, 14−1818)), Signal International, LLC((13−6219, 13−6221, 14−732, 14−1818)), Signal International, LLC filed by Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C.((13−6219, 13−6220, 13−6221, 14−732, 14−1818)), Gulf Coast Immigration Law Center, L.L.C., Malvern C. Burnett, Law Offices of Malvern C. Burnett, A.P.C., Malvern C. Burnett((13−6219, 13−6220, 13−6221, 14−732, 14−1818)).(Reference: 13−6221)(Cerniglia, Timothy) (Entered: 07/03/2015)
658 CROSSCLAIM with Jury Demand against Signal International LLC((13−6220)), Signal International, Inc.((13−6219, 13−6221, 14−732, 14−1818)), Signal International, Inc., Signal International, LLC filed by Gulf Coast Immigration Law Center, L.L.C., Malvern C. Burnett, Law Offices of Malvern C. Burnett, A.P.C..(Reference: 14−732)(Cerniglia, Timothy) (Entered: 07/03/2015)
659 CROSSCLAIM with Jury Demand against Signal International, Inc., Signal International, LLC filed by Gulf Coast Immigration Law Center, L.L.C., Malvern C. Burnett, Law Offices of Malvern C. Burnett, A.P.C..(Reference: 14−1818)(Cerniglia, Timothy) (Entered: 07/03/2015)
660 CROSSCLAIM with Jury Demand against Signal International, Inc., Signal International, LLC filed by Gulf Coast Immigration Law Center, L.L.C., Malvern C. Burnett, Law Offices of Malvern C. Burnett, A.P.C..(Reference: 14−2826)(Cerniglia, Timothy) (Entered: 07/03/2015)
661 CROSSCLAIM with Jury Demand against Signal International, Inc., Signal International, LLC filed by Gulf Coast Immigration Law Center, L.L.C., Malvern C. Burnett, Law Offices of Malvern C. Burnett, A.P.C..(Reference: 14−2826)(Cerniglia, Timothy) (Entered: 07/03/2015)
662 CROSSCLAIM with Jury Demand against Signal International, Inc., Signal International, LLC filed by Gulf Coast Immigration Law Center, L.L.C., Malvern C. Burnett, Law Offices of Malvern C. Burnett, A.P.C..(Reference: 14−2811)(Cerniglia, Timothy) (Entered: 07/03/2015)
663 CROSSCLAIM with Jury Demand against Signal International, Inc., Signal International, LLC filed by Gulf Coast Immigration Law Center, L.L.C., Malvern C. Burnett, Law Offices of Malvern C. Burnett, A.P.C..(Reference: 15−2295)(Cerniglia, Timothy) (Entered: 07/03/2015)
664 CROSSCLAIM with Jury Demand against Signal International, Inc., Signal International, LLC filed by Gulf Coast Immigration Law Center, L.L.C., Malvern C. Burnett, Law Offices of Malvern C. Burnett, A.P.C..(Reference: 15−2296)(Cerniglia, Timothy) (Entered: 07/03/2015)
665 CROSSCLAIM with Jury Demand against Signal International, Inc., Signal International, LLC filed by Gulf Coast Immigration Law Center, L.L.C., Malvern C. Burnett, Law Offices of Malvern C. Burnett, A.P.C..(Reference: 15−2297)(Cerniglia, Timothy) (Entered: 07/03/2015)
666 ORDER granting 649 Motion for Leave to File Cross Claims Against Signal. Signed by Judge Susie Morgan. (Reference: 13−6218)(bwn) (Entered: 07/06/2015)
667 ORDER granting 650 Motion for Leave to File Cross Claims Against Signal. Signed by Judge Susie Morgan. (Reference: 13−6219)(bwn) (Entered: 07/06/2015)
668 ORDER granting 651 Motion for Leave to File Cross Claims Against Signal. Signed by Judge Susie Morgan. (Reference: 13−6220)(bwn) (Entered: 07/06/2015)

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07/06/2015 07/06/2015 07/06/2015 07/06/2015 07/13/2015
07/13/2015 07/13/2015 07/14/2015
07/14/2015
07/15/2015 07/15/2015 07/15/2015 07/16/2015
07/28/2015 07/28/2015

669 ORDER granting 652 Motion for Leave to File Cross Claims Against Signal. Signed by Judge Susie Morgan. (Reference: 13−6221)(bwn) (Entered: 07/06/2015)
670 ORDER granting 653 Motion for Leave to File Cross Claims Against Signal. Signed by Judge Susie Morgan. (Reference: 14−732)(bwn) (Entered: 07/06/2015)
671 ORDER granting 654 Motion for Leave to File Cross Claims Against Signal. Signed by Judge Susie Morgan. (Reference: 14−1818)(bwn) (Entered: 07/06/2015)
672 CROSSCLAIM with Jury Demand against Signal International, Inc., Signal International, LLC filed by Sachin Dewan, Dewan Consultants Pvt. Ltd.(Reference: All Cases)(bwn) (Entered: 07/06/2015)
673 NOTICE OF FILING BANKRUPTCY by Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Signal International, LLC. (Attachments: # 1 Exhibit A−1, # 2 Exhibit A−2, # 3 Exhibit A−3, # 4 Exhibit A−4, # 5 Exhibit A−5)(Reference: 13−6218, 13−6219, 13−6220, 13−6221, 14−732 & 14−1818))(Hangartner, Erin) (Entered: 07/13/2015)
674 EXPARTE/CONSENT MOTION to Appear Pro Hac Vice for Kirk A. Wilkinson (Filing fee $ 100 receipt number 053L−4932388) by Plaintiffs. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Proposed Order)(Reference: 13−6218)(Grimsal, A.) (Entered: 07/13/2015)
675 EXPARTE/CONSENT MOTION to Appear Pro Hac Vice for Michael G. Romey (Filing fee $ 100 receipt number 053L−4932389) by Plaintiffs. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Proposed Order)(Reference: 13−6218)(Grimsal, A.) (Entered: 07/13/2015)
676 TRANSCRIPT of Status Conference held on June 15, 2015 before Judge Susie Morgan. Court Reporter/Recorder Cathy Pepper, Telephone number 504−589−7779. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Recorder before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Parties have 21 days from the filing of this transcript to file with the Court a Redaction Request. Release of Transcript Restriction set for 10/13/2015. (Reference: 13−6218)(rsg) (Entered: 07/14/2015)
680 Minute Entry for proceedings held before Judge Susie Morgan: Status Conference held on 7/14/2015. The Court set a trial date for the Achari Plaintiffs' claims against Burnett and Dewan for November 2, 2015 at 9:00 a.m. A pre−trial conference is set for October 20, 2015 at 10:00 a.m. The parties to this trial shall comply with the following pre−trial deadlines herein. (Reference: All Cases)(bwn) (Entered: 07/17/2015)
677 ORDER granting 674 Motion to Appear Pro Hac Vice as to Kirk A. Wilkinson. Signed by Judge Susie Morgan. (Reference: 13−6218)(bwn) (Entered: 07/15/2015)
678 ORDER granting 675 Motion to Appear Pro Hac Vice as to Michael A. Romey. Signed by Judge Susie Morgan. (Reference: 13−6218)(bwn) (Entered: 07/15/2015)
679 ORDER Continuation Settlement Conference set for 9/9/2015 02:30 PM before Magistrate Judge Daniel E. Knowles III. Signed by Magistrate Judge Daniel E. Knowles, III.(Reference: 13−6218)(plh) (Entered: 07/15/2015)
681 ORDER DENYING WITHOUT PREJUDICE 555 Motion in Limine To Exclude Plaintiffs From Referring To Alleged Oral Promises As Contracts; DENYING WITHOUT PREJUDICE 557 Motion in Limine to Authorizing Cross−Examination of Plaintiffs on Post−Signal Lives; DENYING WITHOUT PREJUDICE 558 Motion in Limine to Exclude Evidence Related to OSHA Applicability and Compliance; DENYING WITHOUT PREJUDICE 559 Motion in Limine to Exclude Certain Types of Legal Coercion Evidence. Signed by Judge Susie Morgan on 7/15/2015. (Reference: All Cases)(bwn) (Entered: 07/17/2015)
682 EXPARTE/CONSENT MOTION to Withdraw Mostafa M. Abdelkarim as Attorney by Pravin Kumar Singh, Radhakrishnan Nair Mangalathu Vasukuttan. (Attachments: # 1 Proposed Order)(Reference: 14−732)(Grimsal, A.) (Entered: 07/28/2015)
683 ORDER granting 682 Motion to Withdraw as Attorney Mona V. Mehta. Signed by Judge Susie Morgan on 7/28/2015. (Reference: 14−732)(cms) (Entered: 07/29/2015)

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 241 of 250

08/04/2015 08/06/2015 08/21/2015 08/25/2015 09/03/2015 09/03/2015 09/08/2015 09/09/2015 09/09/2015 09/09/2015
09/10/2015 09/21/2015 09/27/2015 09/28/2015 09/28/2015 09/28/2015

684 EXPARTE/CONSENT MOTION to Enroll as Counsel of Record for Meredith S. Grabill by Plaintiffs. (Attachments: # 1 Proposed Order)(Reference: 13−6218; 13−6219; 13−6220; 13−6221; 14−732)(Grimsal, A.) (Entered: 08/04/2015)
685 ORDER granting 684 Motion to Enroll as Counsel of Record for Plaintiffs. Signed by Judge Susie Morgan. (Reference: 13−6218; 13−6219; 13−6220; 13−6221; 14−732)(bwn) (Entered: 08/06/2015)
686 EXPARTE/CONSENT MOTION to Change Trial Attorney Designation from A. Gregory Grimsal to Meredith S. Grabill by Plaintiffs. (Attachments: # 1 Proposed Order)(Reference: 13−6221; 13−6220; 14−732)(Grimsal, A.) (Entered: 08/21/2015)
687 ORDER granting 686 Motion to Change Trial Attorney Designation. Signed by Judge Susie Morgan. (Reference: 13−6220; 13−6221; and 14−732)(bwn) (Entered: 08/25/2015)
688 EXPARTE/CONSENT MOTION to Withdraw Tricia Beckles as Attorney by Thomas Plaintiffs. (Attachments: # 1 Proposed Order)(Reference: 14−1818)(Beckles, Tricia) (Entered: 09/03/2015)
689 EXPARTE/CONSENT MOTION to Withdraw Jacob A. Walker as Attorney by Chakkiyattil Plaintifffs. (Attachments: # 1 Proposed Order)(Reference: 13−6219).(Walker, Jacob) (Entered: 09/03/2015)
690 ORDER granting 688 Motion to Withdraw as Attorney. Attorney Tricia Beckles terminated. Signed by Judge Susie Morgan. (Reference: 14−1818)(bwn) (Entered: 09/08/2015)
691 ORDER granting 689 Motion to Withdraw as Attorney. Attorney Jacob A. Walker terminated. Signed by Judge Susie Morgan on 9/8/2015. (Reference: 13−6219)(bwn) (Entered: 09/09/2015)
692 Minute Entry for proceedings held before Magistrate Judge Daniel E. Knowles, III: Settlement Conference held on 9/9/2015. Settlement can not be reached at this time. (Reference: 13−6218)(plh) (Entered: 09/10/2015)
694 Minute Order. Proceedings held before Judge Susie Morgan: Status Conference held on 9/9/2015. For the reasons stated orally and on the record, the David Plaintiffs motion in limine to exclude evidence of Signals post−lawsuit conduct and certain other evidence 547 is hereby DENIED AS MOOT. Furthermore, the Plaintiffs motion in limine to exclude evidence concerning any non−retaliatory basis for Signals termination of Jacob Joseph Kadakkarapally 548 is also hereby DENIED AS MOOT. The parties must comply with the pre−trial deadlines as set forth herein. (Reference: All Cases)(bwn) (Entered: 09/10/2015)
693 ORDER granting in part and denying in part 546 Motion in Limine to Exclude Inadmissible Evidence and Testimony of Plaintiffs' and Signal's Immigration Law Experts. Signed by Judge Susie Morgan on 9/9/2015. (Reference: 13−6218)(bwn) (Entered: 09/10/2015)
695 ORDER Continuation Settlement Conference set for 9/28/2015 09:30 AM before Magistrate Judge Daniel E. Knowles III. Signed by Magistrate Judge Daniel E. Knowles, III.(Reference: 13−6218)(plh) (Entered: 09/21/2015)
696 Witness and Exhibit List by Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C., Law Offices of Malvern C. Burnett, A.P.C.. (Reference: 13−6218)(Cerniglia, Timothy) (Entered: 09/27/2015)
697 Minute Entry for proceedings held before Magistrate Judge Daniel E. Knowles, III: Settlement Conference held on 9/28/2015. Settlement can not be reached at this time. (Reference: 13−6218)(plh) (Entered: 09/28/2015)
698 Final Witness List by Sachin Dewan, Dewan Consultants Pvt. Ltd.. (Reference: 13−6218)(Shapiro, Stephen) (Entered: 09/28/2015)
699 Final Exhibit List by Sachin Dewan, Dewan Consultants Pvt. Ltd.. (Reference: 13−6218)(Shapiro, Stephen) (Entered: 09/28/2015)

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 242 of 250

09/28/2015 09/28/2015 10/02/2015 10/05/2015 10/13/2015 10/13/2015
10/14/2015 10/14/2015 10/20/2015
11/06/2015 12/02/2015
12/14/2015

700 Witness List by All Plaintiffs. (Reference: 13−6218)(Grimsal, A.) (Entered: 09/28/2015)
701 Exhibit List by All Plaintiffs. (Reference: 13−6218)(Grimsal, A.) (Entered: 09/28/2015)
702 EXPARTE/CONSENT Joint MOTION for Conditional Dismissal by Achari Plaintiffs, Chakkiyattil Plaintiffs, Malvern C. Burnett, Law Offices of Malvern C. Burnett, A.P.C., and Gulf Coast Immigration Law Center. (Attachments: # 1 Proposed Order)(Reference: 13:6218; 13:6219)(Grimsal, A.) Modified on 10/5/2015 to edit filers (bwn). (Entered: 10/02/2015)
703 ORDER granting 702 Joint Motion for Conditional Dismissal as against Malvern C. Burnett, the Law Offices of Malvern C. Burnett, PLC, and the Gulf Coast Immigration Law Center. Signed by Judge Susie Morgan on 10/5/2015. (Reference: 13−6218; 13−6219)(bwn) (Entered: 10/06/2015)
704 Proposed Pretrial Order by Dewan Defendants and by All Plaintiffs (Attachments: # 1 Exhibit A−J, # 2 Exhibit K, # 3 Exhibit L, # 4 Exhibit L−1)(Reference: 13−6218)(Grimsal, A.) (Entered: 10/13/2015)
705 Minute Entry for proceedings held before Judge Susie Morgan: Telephone Status Conference held on 10/13/2015. IT IS ORDERED that the trial date in the Achari matter is continued to January 19, 2016, at 9:00 a.m. IT IS FURTHER ORDERED that the pre−trial conference scheduled for October 20, 2015, at 10:00 a.m., is cancelled and hereby re−set for January 6, 2016, at 10:00 a.m. IT IS FURTHER ORDERED that the parties comply with the amended pre−trial deadlines as set forth herein. (Reference: 13−6218)(bwn) (Entered: 10/14/2015)
706 ORDER− IT IS ORDERED that a telephone status conference is hereby set in all cases for Tuesday, October 20, 2015, at 10:00 a.m. The Courts judicial assistant will provide the call−in instructions necessary to participate in the conference via telephone. Signed by Judge Susie Morgan on 10/13/2015.(Reference: All Cases)(bwn) (Entered: 10/14/2015)
707 ORDER − IT IS ORDERED that the trial in the Chakkiyattil (13−6219), which is currently scheduled for January 4, 2016, is CONTINUED WITHOUT DATE. IT IS FURTHER ORDERED that the pre−trial conference scheduled for December 14, 2015, is hereby CANCELLED. Signed by Judge Susie Morgan.(Reference: 13−6219)(bwn) (Entered: 10/14/2015)
708 Minute Entry for proceedings held before Judge Susie Morgan: Telephone Status Conference held on 10/20/2015. IT IS ORDERED that the submission date on Plaintiffs re−urged bill of costs is continued to Friday, October 30, 2015, at 5:00 p.m. IT IS FURTHER ORDERED that the Dewan Defendants may file a reply memorandum in further support of their motion for supersedeas bond by Friday, October 30, 2015, at 5:00 p.m. IT IS FURTHER ORDERED that counsel for Signal notify the Court of the status of Signals appeal by Tuesday, November 3, 2015, at 5:00 p.m. (Reference: All Cases)(bwn) (Entered: 10/21/2015)
709 ORDER − Due to a conflict in the Courts calendar, the status conference in the above matter presently scheduled for Monday, November 9, 2015, at 1:00 p.m. is CONTINUED to Monday, December 14, 2015, at 1:00 p.m. and hereby CONVERTED to a telephone status conference. The Court will provide the parties with the call−in instructions necessary to participate in the conference via telephone. Signed by Judge Susie Morgan.(Reference: All Cases)(bwn) (Entered: 11/06/2015)
710 ORDER AND REASONS re 504 Motion for Summary Judgment − IT IS ORDERED that the Dewan Defendants Motions for Summary Judgment are hereby GRANTED IN PART and DENIED IN PART. Signals non−indemnity crossclaims are barred by the doctrine of res judicata. Signals crossclaims for indemnity against the Burnett and Dewan Defendants are, for the reasons stated above, not barred by the doctrine of res judicata. Signed by Judge Susie Morgan on 12/1/2015. (Reference: 13−6218)(bwn) (Entered: 12/02/2015)
711 Minute Entry for proceedings held before Judge Susie Morgan: Telephone Status Conference held on 12/14/2015. IT IS ORDERED that all pre−trial deadlines and trial dates in all actions are hereby VACATED. IT IS FURTHER ORDERED that counsel

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12/15/2015 12/15/2015 12/18/2015 12/18/2015 12/21/2015 12/22/2015 12/23/2015
12/28/2015 12/28/2015
12/28/2015 12/29/2015 01/20/2016

for the Burnett Defendants and the Dewan Defendants shall file motions for summary judgment on Signals remaining crossclaims no later than Monday, December 28, 2015, at 5:00 p.m. IT IS FURTHER ORDERED that Signal shall file a response to the Burnett and Dewan Defendants motions for summary judgment no later than Friday, January 15, 2016, at 5:00 p.m. (Reference: All Cases)(bwn) (Entered: 12/14/2015)
712 EXPARTE/CONSENT Joint MOTION for Conditional Dismissal by Achari Plaintiffs, Sachin Dewan, and Dewan Consultants Pvt. Ltd. (Attachments: # 1 Proposed Order)(Reference: 13−6218)(Grimsal, A.) Modified on 12/16/2015 to edit filers (bwn). (Entered: 12/15/2015)
713 EXPARTE/CONSENT Joint MOTION for Extension of Conditional Dismissal by Achari Plaintiffs, Chakkiyattil Plaintiffs, and Burnett Defendants. (Attachments: # 1 Proposed Order)(Reference: 13:6218; 13:6219)(Grimsal, A.) Modified on 12/16/2015 to edit filers (bwn). (Entered: 12/15/2015)
714 ORDER granting 712 Motion for Conditional Dismissal. IT IS FURTHER ORDERED that this action be and is hereby dismissed as against the Dewan Defendants, without costs and without prejudice to the right, upon good cause shown, within 60 days, to reopen the action if the settlement is not consummated. Signed by Judge Susie Morgan on 12/16/2015. (Reference: 13−6218)(bwn) (Entered: 12/18/2015)
715 ORDER granting 713 Motion for Extension of Conditional Dismissal. Signed by Judge Susie Morgan on 12/16/2015. (Reference: 13−6218 and 13−6219)(bwn) (Entered: 12/18/2015)
716 EXPARTE/CONSENT MOTION to Withdraw Joshua Asher as Attorney by Pravin Kumar Singh, Radhakrishnan Nair Mangalathu Vasukuttan. (Attachments: # 1 Proposed Order)(Reference: 14−732)(Grimsal, A.) (Entered: 12/21/2015)
717 ORDER granting 716 Motion to Withdraw as Attorney. Attorney Joshua D. Asher terminated. Signed by Judge Susie Morgan. (Reference: 14−732)(bwn) (Entered: 12/22/2015)
718 EXPARTE/CONSENT MOTION for Leave to File Excess Pages on Motion for Summary Judgment by Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C. and Law Offices of Malvern C. Burnett, A.P.C. (Attachments: # 1 Proposed Order, # 2 Proposed Memorandum in Support, # 3 Proposed Motion, # 4 Proposed Statement of Uncontested Facts, # 5 Proposed Exhibit 1, # 6 Proposed Exhibit 2, # 7 Proposed Exhibit 3, # 8 Proposed Notice of Submission, # 9 Proposed Order)(Reference: All Cases)(Cerniglia, Timothy) (Entered: 12/23/2015)
719 ORDER granting 718 Motion for Leave to File Excess Pages. Signed by Judge Susie Morgan. (Reference: 13−6218,13−6219, 13−6220; 13−6221; 14−427, 14−1818)(cml) (Entered: 12/28/2015)
720 MOTION for Summary Judgment of Signals Cross Claims for Indemnity by Malvern C. Burnett, Law Offices of Malvern C. Burnett, A.P.C.. Motion(s) will be submitted on 1/27/2016. (Attachments: # 1 Memorandum in Support, # 2 Statement of Contested/Uncontested Facts, # 3 Exhibit, # 4 Notice of Submission, # 5 Proposed Order)(Reference: 13−6218,13−6219, 13−6220; 13−6221; 14−427, 14−181)(cml) (Entered: 12/28/2015)
721 EXPARTE/CONSENT MOTION to Join the Burnett Defendants' Motion for Summary Judgment on Signal's Cross Claim for Indemnity and for Reconsideration of Motion for Summary Judgment on the Basis of Claim Preclusion by Sachin Dewan, Dewan Consultants Pvt. Ltd.. (Attachments: # 1 Proposed Order)(Reference: 13−6219, 13−6220, 13−6221, 14−472, 14−1818)(Shapiro, Stephen) (Entered: 12/28/2015)
722 ORDER granting 721 Motion to join the Burnett Defendants Motion for Summary Judgment. Signed by Judge Susie Morgan. (Reference: All Cases)(cml) (Entered: 12/29/2015)
723 EXPARTE/CONSENT MOTION to Substitute Party. Party World Marine, LLC to be substituted in place of Signal International, LLC, Signal International, Inc., Signal International Texas, G.P., Signal International Texas, L.P. by Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Signal International, LLC. (Attachments: # 1 Proposed Order)(Reference: 13−6219, 13−6220,

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 244 of 250

01/20/2016 01/20/2016
01/21/2016
01/21/2016 01/21/2016 02/01/2016 02/03/2016
02/04/2016 02/15/2016 02/15/2016 02/19/2016 02/19/2016 04/19/2016 04/19/2016 04/21/2016 04/21/2016

13−6221, 14−732, 14−1818)(Hangartner, Erin) (Entered: 01/20/2016)
724 ***STRICKEN*** NOTICE of Appearance by Erin Casey Hangartner on behalf of World Marine, LLC. (Reference: 13−6219, 13−6220, 13−6221, 14−732, 14−1818)Attorney Erin Casey Hangartner added to party World Marine, LLC(pty:crc).(Hangartner, Erin) Modified on 1/21/2016 (bwn). (Entered: 01/20/2016)
725 RESPONSE to Motion filed by World Marine, LLC re 720 MOTION for Summary Judgment, 721 MOTION to Join the Burnett Defendants' Motion for Summary Judgment on Signal's Cross Claim for Indemnity and for Reconsideration of Motion for Summary Judgment on the Basis of Claim Preclusion . (Reference: 13−6219, 13−6220, 13−6221, 14−732, 14−1818)(Hangartner, Erin) (Entered: 01/20/2016)
726 Correction of Docket Entry by Clerk re 724 Notice of Appearance − Document has been stricken. Notice of Appearance is not the proper form to request representation of a party. All attorneys listed on the Notice have been added as counsel of record. In the future, appearance should be made in the form of a Motion with a proposed order. No further action is necessary. (Reference: All Cases)(bwn) (Entered: 01/21/2016)
727 ORDER granting 723 Motion to Substitute Party. World Marine, LLC added. Signal International, LLC, Signal International Texas, L.P. and Signal International Texas, L.P. terminated. Signed by Judge Susie Morgan. (Reference: All Cases)(bwn) (Entered: 01/21/2016)
728 ORDER granting 720 Motion for Summary Judgment on Cross−Claims. Signed by Judge Susie Morgan. (Reference: All Cases)(bwn) (Entered: 01/21/2016)
729 ORDER DENYING AS MOOT 549 Motion in Limine and 552 Motion in Limine. Signed by Judge Susie Morgan. (Reference: 13−6218)(bwn) (Entered: 02/01/2016)
730 EXPARTE/CONSENT MOTION to Withdraw Hal D. Ungar as Attorney by Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Signal International, LLC. (Attachments: # 1 Proposed Order)(Reference: 13−6218, 13−6219, 13−6220, 13−6221, 14−732, 14−1818)(Hangartner, Erin) (Entered: 02/03/2016)
731 ORDER granting 730 Motion to Withdraw as Attorney. Attorney Hal D. Ungar terminated. Signed by Judge Susie Morgan. (Reference: All Cases)(bwn) (Entered: 02/04/2016)
732 EXPARTE/CONSENT Joint MOTION Extension of conditional dismissal by Plaintiffs. (Attachments: # 1 Proposed Order)(Reference: 13−6218)(Grimsal, A.) Modified on 2/16/2016 (bwn). (Entered: 02/15/2016)
733 EXPARTE/CONSENT Joint MOTION Second Extension of Conditional Dismissal by Plaintffs. (Attachments: # 1 Proposed Order)(Reference: 13/6218; 13−6219)(Grimsal, A.) Modified on 2/16/2016 (bwn). (Entered: 02/15/2016)
734 ORDER granting 732 Motion for Extension of Conditional Dismissal. Signed by Judge Susie Morgan. (Reference: 13−6218)(bwn) (Entered: 02/19/2016)
735 ORDER granting 733 Motion for Second Extension of Conditional Dismissal. Signed by Judge Susie Morgan. (Reference: 13−6218 and 13−6219)(bwn) (Entered: 02/19/2016)
736 EXPARTE/CONSENT Joint MOTION Second Extension of Conditional Dismissal by Plaintiffs (Attachments: # 1 Proposed Order)(Reference: 13−6218)(Grimsal, A.) Modified on 4/19/2016 (clc). (Entered: 04/19/2016)
737 EXPARTE/CONSENT Joint MOTION for Third Extension of Conditional Dismissal by plaintiffs, Malvern C. Burnett, Law Offices of Malvern C. Burnett, A.P.C., Gulf Coast Immigration Law Center, L.L.C. (Attachments: # 1 Proposed Order)(Reference: 13−6218; 13−6219)(Grimsal, A.) Modified on 4/19/2016 (clc). (Entered: 04/19/2016)
738 ORDER granting 736 Motion Second Extension of Conditional Dismissal. Signed by Judge Susie Morgan on 4/21/16. (Reference: 13−6218)(clc) (Entered: 04/22/2016)
739 ORDER granting 737 Motion for Third Extension of Conditional Dismissal. Signed by Judge Susie Morgan on 4/21/16. (Reference: 13−6218, 13−6219)(clc) (Entered:

Case: 2:13-cv-6218 As of: 10/15/2017 04:23 PM CDT 245 of 250

05/31/2016 06/16/2016 06/20/2016 06/20/2016 06/21/2016 06/21/2016 06/24/2016 08/08/2016
08/22/2016 08/22/2016 08/26/2016
08/26/2016

04/22/2016)
740 ORDER − A telephone status settlement conference is scheduled in the above−captioned case on MONDAY, June 13, 2016, at 9:30 A.M. with Magistrate Judge Daniel E. Knowles III. Signed by Magistrate Judge Daniel E. Knowles, III.(Reference: 13−6218)(bwn) (Entered: 05/31/2016)
741 Minute Entry for proceedings held before Magistrate Judge Daniel E. Knowles, III: Status Conference to discuss settlement was held on 6/13/2016. Continuation Telephone Status Settlement Conference set for 6/24/2016 09:30 AM before Magistrate Judge Daniel E. Knowles III. (Reference: 13−6218)(cms) (Entered: 06/16/2016)
742 EXPARTE/CONSENT Joint MOTION Fourth Extension of Conditional Dismissal by Plaintiffs. (Attachments: # 1 Proposed Order)(Reference: 13:6218)(Grimsal, A.) (Entered: 06/20/2016)
743 EXPARTE/CONSENT Joint MOTION Third Extension of Conditonal Dismissal by Plaintiffs. (Attachments: # 1 Proposed Order)(Reference: 13:6218)(Grimsal, A.) (Entered: 06/20/2016)
744 ORDER granting 742 Motion to Extend Conditional Dismissal. Signed by Judge Susie Morgan. (Reference: 13−6218 & 13−6219)(bwn) (Entered: 06/21/2016)
745 ORDER granting 743 Motion to Extend Conditional Dismissal. Signed by Judge Susie Morgan. (Reference: 13−6218)(bwn) (Entered: 06/21/2016)
746 Minute Entry for proceedings held before Magistrate Judge Daniel E. Knowles, III: Status Conference to discuss settlement held on 6/24/2016. Continuation Telephone Status Settlement Conference set for 6/29/2016 02:30 PM before Magistrate Judge Daniel E. Knowles III. (Reference: 13−6218)(cms) (Entered: 06/24/2016)
747 ORDER − IT IS ORDERED that plaintiffs Srinivasa Reddy Dalli and Venkata Satya Sivagi Rao Talabathulla shall communicate with their respective counsel within sixty (60) days of the date this Order is filed into the record to communicate with their counsel and/or or this Court, and advise whether they will participate in the pending settlement. The failure of these plaintiffs to communicate with their counsel and/or this Court, as ordered, will result in the immediate dismissal with prejudice of all pending claims these plaintiffs have against the Dewan Defendants due to failure to prosecute this case pursuant to Rule 41 of the Federal Rules of Civil Procedure. Signed by Judge Susie Morgan on 8/5/16. (Attachments: # 1 Attachment 1, # 2 Attachment 2)(Reference: (13−6218 c/w 13−6219, 13−6220, 13−6221, 14−472, 14−1818)(clc) (Entered: 08/08/2016)
748 EXPARTE/CONSENT Fifth MOTION Extension of Conditional Dismissal by Plaintiffs. (Attachments: # 1 Proposed Order)(Reference: 13−6218)(Grimsal, A.) (Entered: 08/22/2016)
749 EXPARTE/CONSENT Fourth MOTION Extension of Conditional Dismissal by Plaintiffs. (Attachments: # 1 Proposed Order)(Reference: 13−6218)(Grimsal, A.) (Entered: 08/22/2016)
750 ORDER granting 749 Motion for Fourth Extension of Conditional Dismissal. IT IS FURTHER ORDERED that the conditional dismissal of this action as against the Dewan Defendants is hereby extended for an additional sixty (60) days from the date of this order. The conditional dismissal is without costs and without prejudice to the right, within sixty (60) days of the date of this order, to file a motion for summary judgment enforcing the settlement or to reopen this matter if settlement is not consummated. IT IS FURTHER ORDERED that this Court will retain jurisdiction of this matter pursuant to Kokkonen v. Guardian Life, 511 U.S. 375, 114 S.Ct. 1673 (1994). Signed by Judge Susie Morgan on 8/26/16. (Reference: 13−6218)(cg) (Entered: 08/26/2016)
751 ORDER granting 748 Motion for Fifth Extension of Conditional Dismissal. IT IS FURTHER ORDERED that the conditional dismissal of these actions as against the Burnett Defendants, Nos. 13−6218 and 13−6219, is hereby extended, without prejudice to the right, within sixty (60) days of the date of this order, to file a motion for summary judgment enforcing the settlement or to reopen either of these matters if

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10/24/2016 10/24/2016 10/25/2016
10/25/2016
11/16/2016 11/28/2016 11/30/2016 11/30/2016 12/12/2016 12/15/2016 12/29/2016
01/23/2017

settlement is not consummated. IT IS FURTHER ORDERED that this Court will retain jurisdiction of these matters pursuant to Kokkonen v. Guardian Life, 511 U.S. 375, 114 S.Ct. 1673 (1994). Signed by Judge Susie Morgan on 8/26/16. (Reference: 13−6218, 13−6219)(cg) (Entered: 08/26/2016)
752 EXPARTE/CONSENT Joint MOTION Fifth Extension of Conditional Dismissal by Plaintiffs. (Attachments: # 1 Proposed Order)(Reference: 13−6218)(Grimsal, A.) (Entered: 10/24/2016)
753 EXPARTE/CONSENT Joint MOTION Sixth Extension of Conditional Dismissal by Plaintiffs. (Attachments: # 1 Proposed Order)(Reference: 13−6218)(Grimsal, A.) (Entered: 10/24/2016)
754 ORDER granting 752 Motion for Fifth Extension of Conditional Dismissal. IT IS FURTHER ORDERED that the conditional dismissal of this action asagainst the Dewan Defendants is hereby extended for an additional ninety (90) days from the date of this order. The conditional dismissal is without costs and without prejudice to the right, within ninety (90) days of the date of this order, to file a motion for summary judgment enforcing the settlement or to reopen this matter if settlement is not consummated. Signed by Judge Susie Morgan on 10/25/2016. (Reference: 13−6218)(cg) (Entered: 10/25/2016)
755 ORDER granting 753 Motion for Sixth Extension of Conditional Dismissal. IT IS FURTHER ORDERED that the conditional dismissal of these actions asagainst the Burnett Defendants, Nos. 13−6218 and 13−6219, is hereby extended, without prejudice to the right, within ninety (90) days of the date of this order, to file a motion for summary judgment enforcing the settlement or to reopen either of these matters if settlement is not consummated. Signed by Judge Susie Morgan on 10/25/2016. (Reference: 13−6218)(cg) (Entered: 10/25/2016)
756 EXPARTE/CONSENT MOTION to Withdraw Brian C. Roux as Attorney by Signal International Texas, G.P., Signal International Texas, L.P., Signal International, Inc., Signal International, LLC. (Attachments: # 1 Proposed Order)(Reference: 13−6219, 13−6220, 13−6221, 14−732, 14−1818)(Hangartner, Erin) (Entered: 11/16/2016)
757 EXPARTE/CONSENT MOTION to Withdraw Katelyn M. Beaudette as Attorney by Plaintiffs. (Attachments: # 1 Proposed Order)(Reference: 13−6218)(Grimsal, A.) (Entered: 11/28/2016)
758 ORDER granting 756 Motion to Withdraw as Attorney. Attorney Brian C. Roux terminated. Signed by Judge Susie Morgan on 11/30/2016. (Reference: all cases)(cg) (Entered: 11/30/2016)
759 ORDER granting 757 Motion to Withdraw as Attorney. Attorney Katelyn M. Beaudette terminated. Signed by Judge Susie Morgan on 11/30/216. (Reference: 13−6218)(cg) (Entered: 11/30/2016)
760 EXPARTE/CONSENT MOTION for Leave to File Proposed Judgment by Sachin Dewan, Dewan Consultants Pvt. Ltd.. (Attachments: # 1 Proposed Order, # 2 Proposed Pleading Proposed Judgment)(Reference: All)(Shapiro, Stephen) (Entered: 12/12/2016)
761 ORDER granting 760 Motion for Leave to File Proposed Judgment. Signed by Judge Susie Morgan on 12/14/2016. (Reference: all cases)(cg) (Entered: 12/15/2016)
762 JUDGMENT as per herein − IT IS ORDERED, ADJUDGED, AND DECREED that any and all causes of action and/or claims plaintiffs Srinivasa Reddy Dalli and Venkata Satya Sivagi Rao Talabathulla had, or may have had, against Sachin Dewan and/or Dewan Consultants Pvt. Ltd. in this Court are hereby dismissed with prejudice for failure to prosecute their claims pursuant to Rule 41 of the Federal Rules of Civil Procedure. Signed by Judge Susie Morgan on 12/29/2016.(Reference: all cases)(cg) (Entered: 12/29/2016)
763 EXPARTE/CONSENT Joint MOTION Seventh Extension of Conditional Dismissal by Archari Plaintiffs and Chakkiyattil Plaintiffs and Burnett Defendants. (Attachments: # 1 Proposed Order)(Reference: 13−6218, 13−6219)(Grimsal, A.) Modified on 1/23/2017 (cg). (Entered: 01/23/2017)

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01/23/2017 01/25/2017 01/25/2017 02/24/2017
03/01/2017 03/06/2017

764 EXPARTE/CONSENT Joint MOTION Sixth Extension of Conditional Dismissal by Achari Plaintiffs and Dewan Defendants (Attachments: # 1 Proposed Order)(Reference: 13−6218)(Grimsal, A.) Modified on 1/23/2017 (cg). (Entered: 01/23/2017)
765 ORDER granting in part 764 Motion Sixth Extension of Conditional Dismissal as against Defendants Sachin Dewan and Dewan Consultants Pvt. Ltd. IT IS FURTHER ORDERED that the conditional dismissal of this action as against the Dewan Defendants is hereby extended for an additional thirty (30) days from the date of this order. The conditional dismissal is without costs and without prejudice to the right, within thirty (30) days of the date of this order, to file a motion for summary judgment enforcing the settlement or to reopen this matter if settlement is not consummated. IT IS FURTHER ORDERED that this Court will retain jurisdiction of this matter pursuant to Kokkonen v. Guardian Life, 511 U.S. 375, 114 S.Ct. 1673 (1994). Signed by Judge Susie Morgan on 1/24/2017. (Reference: 13−6218)(cg) (Entered: 01/25/2017)
766 ORDER granting 763 Motion Seventh Extension of Conditional Dismissal as against Malvern C. Burnett, the Law Offices of Malvern C. Burnett, PLC, and the Gulf Coast Immigration Law Center. IT IS FURTHER ORDERED that the conditional dismissal of these actions as against the Burnett Defendants, Nos. 13−6218 and 13−6219, is hereby extended, without prejudice to the right, within sixty (60) days of the date of this order, to file a motion for summary judgment enforcing the settlement or to reopen either of these matters if settlement is not consummated. IT IS FURTHER ORDERED that this Court will retain jurisdiction of these matters pursuant to Kokkonen v. Guardian Life, 511 U.S. 375, 114 S.Ct. 1673 (1994). Signed by Judge Susie Morgan on 1/24/2017. (Reference: 13−6218, 13−6219)(cg) (Entered: 01/25/2017)
767 EXPARTE/CONSENT Joint MOTION Seventh Extension of Conditional Dismissal by Varghese Varkey Abraham, Lakshmanan Ponnayan Achari, Subhashithan Bahuleyan, Kodakeril Baby Biji, Xavier Disoliyan, Rajankunju Geevarghese, Jomon George, Shaiju Vadakkal George, Praveen Kulathum Muriyi Gopalakrishnan, Mouleswararao Guntamukkala, Eldose Isac, Joy Jacob, Biju John, Shibu Joseph, Thansilas Joseph, Kulath Somanathan Kalayam, Sunilkumar Marottikkal Kuttan, Bhaskaran Sreedharan Kutty, Parshottam Ramchandra Mangani, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Jacob Mazhukkattu Mathew, Johny Mathew, Nandhakumar Nagaraj, Shaji Veluthalakuzhiyil Nanoo, Mangalan Chandrasekharan Pillai, Radhakrishna Pillai Sivarama Pillai, Aby Molathu Poulose, Justin Poulose, Appunni Arul Prakash, Nibu Raju, Sreenivasarao Raparthy, Mookaparambil Itty Raveendranathan, Balwinder Singh, Ranjit Singh, Savinder Singh, Shanmugam Subramanian, Ninan John Tharakan, Kittayi Sunil Kumar Therattil, Moni Panikulangara Thomas, Thenooran Kumaran Unnikrishnan, Benny Chittilappilly Vareed, George Pulikkeparambil Varghese, Kuliyanickal Paily Varghese, Benny Kattukariyil Varkey, Shahi Vijayan, John Yohannan. (Attachments: # 1 Proposed Order)(Reference: 13−6218)(Grimsal, A.) (Entered: 02/24/2017)
768 ORDER granting 767 Motion for Seventh Extension of ConditionalDismissal. IT IS FURTHER ORDERED that the conditional dismissal of this action as against the Dewan Defendants is hereby extended for fourteen (14) days from the date of this order. The conditional dismissal is without costs and without prejudice to the right of the Achari Plaintiffs or the Dewan Defendants, within fourteen (14) days of the date of this order, to file a motion for summary judgment enforcing the settlement or to reopen this matter if settlement is not consummated. IT IS FURTHER ORDERED that this Court will retain jurisdiction of this matter pursuant to Kokkonen v. Guardian Life, 511 U.S. 375, 114 S.Ct. 1673 (1994). Signed by Judge Susie Morgan on 3/1/2017. (Reference: 13−6218)(cg) (Entered: 03/01/2017)
769 EXPARTE/CONSENT MOTION to Withdraw Grant F. Wahlquist as Attorney by Varghese Varkey Abraham, Lakshmanan Ponnayan Achari, Subhashithan Bahuleyan, Kodakeril Baby Biji, Xavier Disoliyan, Rajankunju Geevarghese, Jomon George, Shaiju Vadakkal George, Praveen Kulathum Muriyi Gopalakrishnan, Mouleswararao Guntamukkala, Eldose Isac, Joy Jacob, Biju John, Shibu Joseph, Thansilas Joseph, Kulath Somanathan Kalayam, Sunilkumar Marottikkal Kuttan, Bhaskaran Sreedharan Kutty, Parshottam Ramchandra Mangani, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Jacob Mazhukkattu Mathew, Johny Mathew, Nandhakumar Nagaraj, Shaji Veluthalakuzhiyil Nanoo, Mangalan Chandrasekharan Pillai,

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03/08/2017 03/15/2017
03/23/2017 03/27/2017
03/29/2017

Radhakrishna Pillai Sivarama Pillai, Aby Molathu Poulose, Justin Poulose, Appunni Arul Prakash, Nibu Raju, Sreenivasarao Raparthy, Mookaparambil Itty Raveendranathan, Balwinder Singh, Ranjit Singh, Savinder Singh, Shanmugam Subramanian, Ninan John Tharakan, Kittayi Sunil Kumar Therattil, Moni Panikulangara Thomas, Thenooran Kumaran Unnikrishnan, Benny Chittilappilly Vareed, George Pulikkeparambil Varghese, Kuliyanickal Paily Varghese, Benny Kattukariyil Varkey, Shahi Vijayan, John Yohannan. (Attachments: # 1 Proposed Order)(Reference: 13−6218)(Grimsal, A.) (Entered: 03/06/2017)
770 ORDER granting 769 Motion to Withdraw as Attorney and that Grant F. Wahlquist is permitted to withdraw as counsel of record for the Achari Plaintiffs in this matter. Signed by Judge Susie Morgan on 3/8/2017. (Reference: 13−6218)(cg) (Entered: 03/08/2017)
771 EXPARTE/CONSENT Joint MOTION Eighth Extension of Conditional Dismissal by Varghese Varkey Abraham, Lakshmanan Ponnayan Achari, Subhashithan Bahuleyan, Kodakeril Baby Biji, Xavier Disoliyan, Rajankunju Geevarghese, Jomon George, Shaiju Vadakkal George, Praveen Kulathum Muriyi Gopalakrishnan, Mouleswararao Guntamukkala, Eldose Isac, Joy Jacob, Biju John, Shibu Joseph, Thansilas Joseph, Kulath Somanathan Kalayam, Sunilkumar Marottikkal Kuttan, Bhaskaran Sreedharan Kutty, Parshottam Ramchandra Mangani, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Jacob Mazhukkattu Mathew, Johny Mathew, Nandhakumar Nagaraj, Shaji Veluthalakuzhiyil Nanoo, Mangalan Chandrasekharan Pillai, Radhakrishna Pillai Sivarama Pillai, Aby Molathu Poulose, Justin Poulose, Appunni Arul Prakash, Nibu Raju, Sreenivasarao Raparthy, Mookaparambil Itty Raveendranathan, Balwinder Singh, Ranjit Singh, Savinder Singh, Shanmugam Subramanian, Ninan John Tharakan, Kittayi Sunil Kumar Therattil, Moni Panikulangara Thomas, Thenooran Kumaran Unnikrishnan, Benny Chittilappilly Vareed, George Pulikkeparambil Varghese, Kuliyanickal Paily Varghese, Benny Kattukariyil Varkey, Shahi Vijayan, John Yohannan. (Attachments: # 1 Proposed Order)(Reference: 13−6218)(Grimsal, A.) (Entered: 03/15/2017)
772 ORDERED that the 771 Motion for Eighth Extension of Conditional Dismissal is GRANTED. FURTHER ORDERED that the conditional dismissal of this action as against the Dewan Defendants is hereby extended for fourteen (14) days from the date of this order. The conditional dismissal is without costs and without prejudice to the right of the Achari Plaintiffs or the Dewan Defendants, within fourteen (14) days of the date of this order, to file a motion for summary judgment enforcing the settlement or to reopen this matter if settlement isnot consummated. FURTHER ORDERED that this Court will retain jurisdiction of this matter pursuant to Kokkonen v. Guardian Life, 511 U.S. 375, 114 S.Ct. 1673 (1994). Signed by Judge Susie Morgan on 3/23/2017. (Reference: 13−6218)(clc) (Entered: 03/23/2017)
773 EXPARTE/CONSENT Joint MOTION Eighth Extension of Conditional Dismissal by Varghese Varkey Abraham, Lakshmanan Ponnayan Achari, Subhashithan Bahuleyan, Kodakeril Baby Biji, Xavier Disoliyan, Rajankunju Geevarghese, Jomon George, Shaiju Vadakkal George, Praveen Kulathum Muriyi Gopalakrishnan, Mouleswararao Guntamukkala, Eldose Isac, Joy Jacob, Biju John, Shibu Joseph, Thansilas Joseph, Kulath Somanathan Kalayam, Sunilkumar Marottikkal Kuttan, Bhaskaran Sreedharan Kutty, Parshottam Ramchandra Mangani, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Jacob Mazhukkattu Mathew, Johny Mathew, Nandhakumar Nagaraj, Shaji Veluthalakuzhiyil Nanoo, Mangalan Chandrasekharan Pillai, Radhakrishna Pillai Sivarama Pillai, Aby Molathu Poulose, Justin Poulose, Appunni Arul Prakash, Nibu Raju, Sreenivasarao Raparthy, Mookaparambil Itty Raveendranathan, Balwinder Singh, Ranjit Singh, Savinder Singh, Shanmugam Subramanian, Ninan John Tharakan, Kittayi Sunil Kumar Therattil, Moni Panikulangara Thomas, Thenooran Kumaran Unnikrishnan, Benny Chittilappilly Vareed, George Pulikkeparambil Varghese, Kuliyanickal Paily Varghese, Benny Kattukariyil Varkey, Shahi Vijayan, John Yohannan. (Attachments: # 1 Proposed Order)(Reference: 13−6218)(Grimsal, A.) (Entered: 03/27/2017)
774 ORDERED that the 773 Motion for Eighth Extension of Conditional Dismissal is GRANTED. ORDERED that the conditional dismissal of these actions as against the Burnett Defendants, Nos. 13−6218 and 13−6219, is hereby extended, without prejudice to the right, within fourteen (14) days of the date of this order, to file a motion for summary judgment enforcing the settlement or to reopen either of these

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04/03/2017 04/04/2017 04/05/2017
04/06/2017 04/06/2017
04/06/2017

matters if settlement is not consummated. FURTHER ORDERED that this Court will retain jurisdiction of these matters pursuant to Kokkonen v. Guardian Life, 511 U.S. 375, 114 S.Ct. 1673 (1994). Signed by Judge Susie Morgan on 3/29/2017. (Reference: 13−6219)(clc) (Entered: 03/29/2017)
775 EXPARTE/CONSENT MOTION to Withdraw John C. Low as Attorney by Thampy Putham Parambil Edicula, Sabu Puthukkuttumel Veede Krishnakutty. (Attachments: # 1 Proposed Order)(Reference: 13−6220)(Grimsal, A.) (Entered: 04/03/2017)
776 ORDER granting 775 Motion to Withdraw as Attorney. Attorney John C. Low terminated. Signed by Judge Susie Morgan on 4/3/2017. (Reference: 13−6220)(clc) (Entered: 04/04/2017)
777 EXPARTE/CONSENT MOTION to Appear Pro Hac Vice Shelia Boston (Filing fee $ 100 receipt number 053L−6064454) by Ganapathi Rao Akkireddi, Davis Antony, Saji Chettiyara Baby, Sarma Venkata Satyanarayana Bhiri, Venkatarao Buridi, Sunny Cherian, Philip Pindakadavil George, Zakir Husain Ghulam Husain, Mathew Jackson, Gogy Joseph, Joshy Kaiprampattu Joseph, Shanoj Joseph, Srinu Kalla, Joseph Thomas Kanjiraparambil, Subranarayanan Karuppiah, Maheshwara Rao Molletti, Sivakumar Ramakrishnan Nair, Reghunadhan Palachuvattilpu Narayanannair, Bhaskararao Nimmadala, Babu Karippai Ouseph, Baiju Paul, Rajan Pazhambalakode, Kantibhai Khemabhai Prajapati, Ravi Thammina, Assari Krishnan Thankappan, George Kutty Puthiya P Thomas, David Raju Tuloori, Satyanarayana Vangapandu, Yacob Thachil Varghese, Antoney Tharayil Xavier. (Attachments: # 1 Certificate of Good Standing, # 2 Declaration, # 3 Proposed Order)(Reference: 14−1818)(Stewart, Meredith) (Additional attachment(s) added on 4/6/2017: # 4 Attorney Registration Form) (clc). (Entered: 04/05/2017)
778 ORDER granting 777 Motion to Appear Pro Hac Vice as to Sheila Sabrina Boston. Signed by Judge Susie Morgan on 4/6/2017. (Reference: 14−1818)(clc) (Entered: 04/06/2017)
779 EXPARTE/CONSENT Joint MOTION to Dismiss Burnett Defendants by Varghese Varkey Abraham, Lakshmanan Ponnayan Achari, Subhashithan Bahuleyan, Kodakeril Baby Biji, Xavier Disoliyan, Rajankunju Geevarghese, Jomon George, Shaiju Vadakkal George, Praveen Kulathum Muriyi Gopalakrishnan, Mouleswararao Guntamukkala, Eldose Isac, Joy Jacob, Biju John, Shibu Joseph, Thansilas Joseph, Kulath Somanathan Kalayam, Sunilkumar Marottikkal Kuttan, Bhaskaran Sreedharan Kutty, Parshottam Ramchandra Mangani, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Jacob Mazhukkattu Mathew, Johny Mathew, Nandhakumar Nagaraj, Shaji Veluthalakuzhiyil Nanoo, Mangalan Chandrasekharan Pillai, Radhakrishna Pillai Sivarama Pillai, Aby Molathu Poulose, Justin Poulose, Appunni Arul Prakash, Nibu Raju, Sreenivasarao Raparthy, Mookaparambil Itty Raveendranathan, Balwinder Singh, Ranjit Singh, Savinder Singh, Shanmugam Subramanian, Ninan John Tharakan, Kittayi Sunil Kumar Therattil, Moni Panikulangara Thomas, Thenooran Kumaran Unnikrishnan, Benny Chittilappilly Vareed, George Pulikkeparambil Varghese, Kuliyanickal Paily Varghese, Benny Kattukariyil Varkey, Shahi Vijayan, John Yohannan, Gulf Coast Immigration Law Center, LLC, Law Offices of Malvern C. Burnett, A.P.C., Marlvern C. Burnett. (Attachments: # 1 Proposed Order)(Reference: No. 13−6218 (c/w 13−6219, 13−6220, 13−6221, 14−732, 14−1818); No. 08−1220)(Grimsal, A.) Modified on 4/7/2017 to edit text. (clc). (Entered: 04/06/2017)
780 EXPARTE/CONSENT Joint MOTION to Dismiss /the Dewan Defendants by Varghese Varkey Abraham, Lakshmanan Ponnayan Achari, Subhashithan Bahuleyan, Kodakeril Baby Biji, Xavier Disoliyan, Rajankunju Geevarghese, Jomon George, Shaiju Vadakkal George, Praveen Kulathum Muriyi Gopalakrishnan, Mouleswararao Guntamukkala, Eldose Isac, Joy Jacob, Biju John, Shibu Joseph, Thansilas Joseph, Kulath Somanathan Kalayam, Sunilkumar Marottikkal Kuttan, Bhaskaran Sreedharan Kutty, Parshottam Ramchandra Mangani, Prakash Moses Kanagiah Manonmoni, Adharsan Manuel, Jacob Mazhukkattu Mathew, Johny Mathew, Nandhakumar Nagaraj, Shaji Veluthalakuzhiyil Nanoo, Mangalan Chandrasekharan Pillai, Radhakrishna Pillai Sivarama Pillai, Aby Molathu Poulose, Justin Poulose, Appunni Arul Prakash, Nibu Raju, Sreenivasarao Raparthy, Mookaparambil Itty Raveendranathan, Balwinder Singh, Ranjit Singh, Savinder Singh, Shanmugam Subramanian, Ninan John Tharakan, Kittayi Sunil Kumar Therattil, Moni

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04/06/2017 04/07/2017
04/07/2017 04/17/2017 04/17/2017 04/18/2017 04/18/2017 05/26/2017

Panikulangara Thomas, Thenooran Kumaran Unnikrishnan, Benny Chittilappilly Vareed, George Pulikkeparambil Varghese, Kuliyanickal Paily Varghese, Benny Kattukariyil Varkey, Shahi Vijayan, John Yohannan, Dewan Consultants Pvt. Ltd., Sachin Dewan. (Attachments: # 1 Proposed Order)(Reference: 13−6218 (c/w 13−6219, 13−6220, 13−6221, 14−732, 14−1818); No. 08−1220)(Grimsal, A.) Modified on 4/7/2017 to edit text. (clc). (Entered: 04/06/2017)
783 EXPARTE/CONSENT Motion for Leave to File Document Under Seal (Attachments: # 1 Proposed Order, # 2 Proposed Pleading, # 3 Proposed Pleading, # 4 Proposed Pleading, # 5 Proposed Pleading) (Reference: 13−6218 (c/w 13−6219, 13−6220, 13−6221, 14−732, 14−1818))(clc) . (Entered: 04/07/2017)
781 ORDER granting 779 Motion to Dismiss Malvern C. Burnett, the Law Offices of Malvern C. Burnett, PLC, and the Gulf Coast Immigration Law Center (the Burnett Defendants) with Prejudice. Signed by Judge Susie Morgan on 4/7/2017. (Reference: 13−6218 c/w 13−6219, 13−6220, 13−6221, 14−732, 14−1818)(clc) (Main Document 781 replaced on 4/7/2017) (clc). Modified on 4/7/2017 to correct image. (clc). (Entered: 04/07/2017)
782 ORDER granting 780 Motion to Dismiss the Dewan Defendants without prejudice. Signed by Judge Susie Morgan on 4/7/2017. (Reference: 13−6218 (c/w 13−6219, 13−6220, 13−6221, 14−732, 14−1818))(clc) (Entered: 04/07/2017)
784 Order granting 783 Motion for Leave to File Document Under Seal. Signed by Judge Susie Morgan on 4/17/2017. (Reference: 13−6218 c/w 13−6219, 13−6220, 13−6221)(clc) (Entered: 04/17/2017)
785 EXPARTE/CONSENT Motion to File Document. (Attachments: # 1 Proposed Order, # 2 Proposed Pleading, # 3 Proposed Pleading) (Reference: 13−6218 c/w 13−6219, 13−6220, 13−6221, 14−732, 14−1818)(clc) (Entered: 04/17/2017)
786 Order granting 785 EXPARTE/CONSENT Motion to File Document. Signed by Judge Susie Morgan on 4/18/2017. (Reference: 13−6218, 13−2619, 13−6220, 13−6221,14−732,14−1818)(clc) (Entered: 04/19/2017)
787 Stipulated Judgment as to the Dewan Defendants. (Attachments: # 1 Exhibit) (Reference: 13−6218, 13−2619, 13−6220, 13−6221,14−732,14−1818)(clc) (Entered: 04/19/2017)
788 ORDER: ORDERED that the Clerk of Court mark the above actions closed for statistical purposes. These cases may be reopened upon motion of any party if any of the unlocated plaintiffs are located so that they may be paid pursuant to the settlement agreement. FURTHER ORDERED that the Court shall retain jurisdiction. This order shall not prejudice the rights of the parties to this litigation. Signed by Judge Susie Morgan on 5/26/2017.(Reference: All Cases)(clc) (Entered: 05/30/2017)