Case 2:13-cv-06220-SM-DEK Document 1 Filed 08/07/13 Page 1 of 65

UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF MISSISSIPPI Southern Division
SABU PUTHUKKUTTUMEL VEEDE KRISHNAKUTTY and THAMPY PUTHAM PARAMBIL EDICULA,

SOUTHf_RN DlSmlCT OF MissISSIPPI
FI LE 0

AUG 072013

J T NOBUN CLERK

BY

DE",""

Plaintiffs,

vs.
SIGNAL INTERNATIONAL LLC, INDO-AMERI SOFT L.L.C., KURELLA RAO, GLOBAL RESOURCES, INC., MALVERN C. BURNETT, LAW OFFICES OF MALVERN C. BURNETT, A.P.e., GULF COAST IMMIGRATION LAW CENTER, L.L.e., SACHIN DEWAN, and DEWAN CONSULTANTS PVT. LTD. (a/k/a MEDTECH CONSULTANTS),

CIVIL ACTION No.1. l3rv3lfJ LE-JMR
JURY TRIAL DEMANDED

Defendants. ----------------------------~/

COMPLAINT

Plaintiffs Sabu Puthukkuttumel Veede Krishnakutty ("Sabu") and Thampy Putham

Parambil Edicula ("Thampy") (collectively, "Plaintiffs"), by their undersigned counsel, submit

the following Complaint against Defendants Signal International LLC ("Signal"), Indo-Ameri

Soft L.L.C. ("Indo-Amerisoft"), Kurella Rao ("Rao"), Global Resources, Inc. ("Global"),

Malvern e. Burnett ("Burnett"), the Law Offices of Malvern C. Burnett ("Burnett Law"), Gulf

Coast Immigration Law Center ("Gulf Coast Law"), Sachin Dewan ("Dewan") and Dewan

Consultants Pvt. Ltd. ("Dewan Consultants") (collectively, "Defendants,,).l

NATURE OF THE ACTION I. This is a human trafficking, RICO, civil rights, misrepresentation and contract

action brought by Plaintiffs, foreign workers trafficked into Mississippi, to recover for the

1 Global, Burnett, Burnett Law, Gulf Coast Law, Dewan, and Dewan Consultants are collectively referred to herein as the "Agents."
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unlawful, fraudulent, exploitative and outrageous conduct by Signal, labor brokers IndoAmerisoft and Rao, Global, Burnett, Burnett Law, Gulf Coast Law, Dewan, and Dewan Consultants. Plaintiffs seek declaratory relief and damages.
2. Defendants conspired and worked together to defraud Plaintiffs out of thousands of dollars, falsely promised them assistance in applying for and obtaining permanent residence in the United States to entice them to pay exorbitant fees to Defendants, trafficked them into the United States, forced them to pay to live in squalid and unsanitary conditions that endangered their health and psychological well-being, discriminated against them on the basis of their race, national origin and alienage, and threatened them with financial ruin and adverse immigration action.
3. In the aftermath of the devastation of Hurricane Katrina, Signal, a marine fabrication company, sought to recruit several hundred foreign workers to work as welders and pipefitters for its Pascagoula, Mississippi, and Orange, Texas facilities. Rather than hiring new workers from the Gulf Coast, Signal instead joined an enterprise that falsely promised Indian men legal permanent residence (referred to as "green cards") to create a ready source of cheap labor. Plaintiffs were 2 of approximately 590 men caught up in this deception.
4. Beginning in 2003, labor brokers Indo-Amerisoft and Rao, and the Agents, hatched a conspiracy and scheme, joined by Signal in 2006, to recruit workers from India, including the Plaintiffs. In printed advertisements and in-person meetings in India, Defendants promised the Plaintiffs that in exchange for "recruitment fees" of approximately $\5,000, Defendants would provide Plaintiffs with ajob in the United States and assist them in applying for and receiving a green card.
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5. Lured by Defendants' fraudulent promises of legal and permanent work-based immigration to the United States for themselves and their families, Plaintiffs plunged themselves and their families into debt to take advantage of these seemingly promising opportunities, selling family treasures and other personal and real property, and incurring significant debt at usurious rates. Plaintiffs did this because they believed they would recoup the expense through the high wages they were promised and through the long-term employment opportunities that would be available to them and their families as permanent residents of the United States. Trusting in the veracity of the immigration and work benefits promised by Defendants, Plaintiffs also relinquished stable employment opportunities in India and in the Persian Gulf.
6. In actuality, Defendants' promises to Plaintiffs were illusory, and knowingly false when made. Defendants had not taken, and had no intention of taking, any steps to assist Plaintiffs in applying for or receiving a green card. To the contrary, Signal, with the knowledge and assistance of the other Defendants, 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 Defendants take any steps to assist Plaintiffs in applying for or receiving a green card.
7. Defendants held Plaintiffs' passports and Visas, and threatened, coerced, and defrauded Plaintiffs into paying extraordinary fees for recruitment, immigration processing, and travel. Defendants further caused Plaintiffs to believe that if they did not work for Signal under the auspices of temporary, Signal-restricted H·2B guest worker visas, they would suffer abuse or threatened abuse of the legal process, physical restraint, or other serious harm.
8. Upon arrival at Signal's facilities in Pascagoula, Plaintiffs' plight only worsened. Signal utilized psychological abuse, coercion, and fraud to make Plaintiffs afraid and unable
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to leave Signal's facilities and employ. Plaintiffs were housed in so-called "man camps" so that they would not mix with the Pascagoula community, enduring prison-like conditions that can only be described as inhumane. 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. Signal's private "security guards" patrolled the grounds like prison guards, often preventing the Plaintiffs from leaving the grounds and subjecting Plaintiffs to random searches oftheir person and belongings.
9. 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 their 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. With 24 men living in a trailer at a time, this amounted to over $25,000 per month per trailer being paid to Signal.
10. Non-Indian workers were not subjected to such squalid living conditions, degrading treatment, mandatory "man camp" deductions from their paychecks, or extortionate room and board policies. Plaintiffs also were subjected to unsafe working conditions that non-Indian workers were not subjected to, and were forced to endure anti-Indian invective from Signal personnel, along with threats to deport them if they did not do Signal's every bidding.
11. Consistent with Signal's unrelenting effort to improve its bottom line by transferring as many costs associated with their employment as possible back onto Plaintiffs, Signal never refunded the "recruitment fees" Plaintiffs had paid in exchange for low-paid
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work. Plaintiffs never 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 Plaintiffs.
JURISDICTION AND VENUE
12. This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C.
§ 1331, 18 U.S.C. § 1595(a), 18 U.S.C. § 1964(c), 28 U.S.c. § 1343, and 28 U.S.C. § 1367.
13. This Court has personal jurisdiction over all Defendants pursuant to Miss. Code
§ 13-3-57 and otherwise. Individually and through their agents, associates, attorneys, or
employees, all Defendants have significant contacts with Mississippi.
(a) Defendant Signal maintains a continuing business presence in Mississippi, including, without limitation, two shipyards in Pascagoula, Mississippi, where the Plaintiffs worked and lived and where much of the wrongful conduct alleged herein occurred. (b) Defendant Indo-Amerisoft has substantial business contacts with Mississippi; it traveled to Mississippi in connection with the events described herein (both individually and on behalf of the other Defendants), it committed torts in Mississippi, and it recruited workers and delivered them for employment in Mississippi. (c) Defendant Rao has substantial business contacts with Mississippi; he traveled to Mississippi in connection with the events described herein (both individually and on behalf of the other Defendants), he committed torts in Mississippi, and he recruited workers and delivered them for employment in Mississippi. (d) Defendant Global is incorporated under the laws of Mississippi, its principal place of business is located in Mississippi, its sole officer and principal (Michael Pol) resides in Mississippi, and it served as Signal's agent to recruit workers and deliver them for employment in Mississippi. (e) Defendant Burnett practices law and is registered to vote in Mississippi, he contracted with Global and Dewan Consultants in connection with the scheme alleged herein for acts in whole or in part to be performed in Mississippi, and he served as Signal's agent to recruit workers and deliver them for employment in Mississippi.
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(f) Defendant Burnett Law has offices in Mississippi where much of the legal work in furtherance of Defendants' schemes was performed, and it served as Signal's agent to recruit workers and deliver them for employment in Mississippi. (g) Defendant Gulf Coast Law has offices in Mississippi where much of the legal work in furtherance of Defendants' schemes was performed, and it served as Signal's agent to recruit workers and deliver them for employment in Mississippi. (h) Defendant Dewan has substantial business contacts with Mississippi; he traveled to Mississippi in connection with the events described herein (both individually and on behalf of the other Defendants), he committed torts in Mississippi, and he served as Signal's agent to recruit workers and deliver them for employment in Mississippi. (i) Defendant Dewan Consultants has substantial business contacts with Mississippi; it traveled to Mississippi in connection with the events described herein (both individually and on behalf of the other Defendants), it contracted with Global and Burnett in connection with the scheme alleged herein for acts to be performed in whole or in part in Mississippi, and it served as Signal's agent to recruit workers and deliver them for employment in Mississippi.
14. Venue is proper in the Southern District of Mississippi under 18 U.S.c. § 1965
and 28 U.S.C. § 1391 because much of Defendants' trafficking activity, civil rights violations,
fraud, breach of contract, misrepresentations and a substantial portion of the communications,
transactions, events or omissions underlying Plaintiffs' claims occurred in and around the
Pascagoula area.
PARTIES IS. Plaintiff Sabu is an Indian national, ofIndian descent, and is a former H-2B guest
worker who was recruited from India by Defendants between 2003 and 2006 and worked at
Signal's Pascagoula facility after arriving in the United States on or about November 28,
2006. Sabu paid Indo-Amerisoft, Rao and/or the Agents the equivalent of approximately
$15,000 in "recruitment fees" based on the false promise that they would assist him in
applying for and receiving a green card. Sabu also was forced to pay additional "fees"
directly to Dewan, Michael Pol and Burnett as well as fees for skills tests and medical exams.
Sabu further incurred transportation expenses each time he was required to travel outside of
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his home in Kerala, India to attend a recruitment meeting, deliver payments, or take a skills test or exam. Sabu was subjected to discriminatory, dangerous, and abusive treatment upon his arrival at Signal.
16. Plaintiff Thampy is an Indian national, of Indian descent, and is a former H-2B guest worker who was recruited from India by Defendants and worked at Signal's Pascagoula facility after arriving in the United States on or about November 28, 2006. Thampy paid Indo-Amerisoft, Rao and/or the Agents the equivalent of approximately $15,000 in "recruitment fees" based on the false promise that they would assist him in applying for and receiving a green card. Thampy also was forced to pay additional "fees" directly to Dewan, Michael Pol and Burnett as well as fees for skills tests. Thampy further incurred transportation expenses each time he was required to travel outside of his home in India to attend a recruitment meeting, deliver payments, or take a skills test or exam. Thampy was subjected to discriminatory, dangerous, and abusive treatment upon his arrival at Signal.
17. Defendant Signal is a corporation organized under the laws of Delaware, with facilities in the Gulf Coast region, including Pascagoula, Mississippi. Signal provides marine and fabrication services, including offshore drilling rig overhaul, repair, upgrade and conversion.
18. Defendant Global is a corporation organized under the laws of Mississippi, with its principal place of business in Mississippi, that recruits workers from India for employment in the United States. Michael Pol was, at all relevant times, the President of Global, and resides in Mississippi. 2 Upon information and relief, Pol was, at all relevant times, the sole corporate officer and principal of Global. Pol and Global are alter egos.
'On or about June 13, 2013, Pol filed for Chapter 7 Bankruptcy protection in the Southern District of Mississippi.
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19. Defendant Indo-Amerisoft is a corporation organized under the laws of Louisiana that is engaged in the business of recruiting and providing Indian laborers to United States companies and selling opportunities for United States immigration and employment to such laborers.
20. Defendant Rao is the Chairman and Director of Indo-Amerisoft. 21. Defendant Dewan Consultants is a private limited liability company organized under the laws of India. In 2003 or 2004, Dewan Consultants contracted with Global and Burnett through Gulf Coast Law to identify and recruit Indian workers for employment in the United States on permanent residency visas. 22. Defendant Dewan is the Director of Dewan Consultants. 23. Defendant Burnett is an attomey who maintains offices In Ocean Springs, Mississippi. 24. Defendant Burnett Law is a professional law corporation organized under the laws of Louisiana that maintains offices in Ocean Springs, Mississippi. 25. Defendant Gulf Coast Law is a limited liability corporation organized under the laws of Louisiana that maintains offices in Ocean Springs, Mississippi. Burnett is the registered agent of Gulf Coast Law, and upon information and belief, Burnett is the sole member, officer or principal of Gulf Coast Law. 3 26. At all relevant times, Plaintiffs and Defendants were "persons" within the meaning of the Racketeer Influenced and Corrupt Organizations Act ("RICO"), 18 U.S.c. § 1961(3).
3 Burnett, Burnett Law, and Gulf Coast Law operated as a joint venture and/or alter egos, and will be referred to collectively below as "the Burnett Defendants."
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27. At all relevant times, Plaintiffs were engaged in interstate commerce and/or in the production of goods for sale in interstate commerce.
28. At all relevant times, Defendants operated enterprises engaged in interstate commerce or in the production of goods for interstate commerce.
29. Upon information and belief, Defendants Dewan, Dewan Consultants, Global (and its principal Michael Pol) and the Burnett Defendants engaged in a joint venture to conduct and effectuate their shared business interests and activities in the United States.
30. Upon information and belief, the Burnett Defendants, Indo-Amerisoft and Rao engaged in a joint venture to conduct and carry out their shared business interests and activities in India and the United Arab Emirates. This joint venture is in addition to the joint venture described above between the Defendants Dewan, Dewan Consultants, Global and the Burnett Defendants.
31. At all relevant times, Defendants Dewan, Dewan Consultants, Global, and the Burnett Defendants acted as agents of Defendants Signal and/or Indo-Amerisoft and Rao for the purposes of recruiting, obtaining, contracting, transporting and providing Plaintiffs for labor or services.
32. The false promises, collection of exorbitant recruiting fees, and strong-arm tactics of Defendants were, upon information and belief, authorized and/or ratified by Signal, which, in any event, learned in detail of these facts from the very first Indian H-2B workers who arrived at Signal's facilities in the United States as early as late October 2006. Far from taking any corrective measures, Signal ratified and perpetuated the scheme by continuing to facilitate the transportation of further waves of Indian H-2B workers, including Plaintiffs, from November 2006 through April 2007.
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SUBSTANTIVE ALLEGATIONS The Initial Recruitment Process
33. Beginning in 2003 and continuing through at least 2006, Defendants Dewan, Dewan Consultants, and Global placed ads in various newspapers across India and the United Arab Emirates, seeking welders, fitters, and other marine fabrication workers on behalf of various U.S.-based companies and individuals, including Defendants Indo-Amerisoft and Rao.
34. Upon information and belief, Dewan, Dewan Consultants, and Global placed such ads in coordination and agreement with the Burnett Defendants, Indo-Amerisoft and Rao.
35. Upon information and belief, from at least December 2003 through mid-2004, the Agents frequently communicated and consulted via mail, fax, e-mail and telephone to coordinate and direct Defendants' recruitment activities, including advertising efforts on behalf of Indo-Amerisoft and Rao.
36. The advertisements placed by the Agents promised that qualified candidates could obtain legal permanent residence ("green cards") and thereby legally and permanently immigrate to the United States with their families.
PlaintiffSabu's Initial Recruitment 37. In the fall of2003, Plaintiff Sabu saw the advertisement placed by the Agents (on behalf of Indo-Amerisoft and Rao) in the Malayalam Manorama, a local newspaper, stating that there were opportunities for work in the United States and permanent residency visas. The advertisement included a phone number for the offices of Dewan Consultants in Mwnbai. 38. Soon after seeing this advertisement, Sabu contacted the offices of Dewan Consultants and spoke directly with Dewan himself. Dewan confirmed the information in the ad regarding both the job opportunity and the opportunity to obtain legal permanent residency ("green card") in the United States. Dewan told Sabu that upcoming informational meetings
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were going to be held at the Trident Hotel in Cochin, India and encouraged Sabu to attend if he was interested in the opportunity.
39. Sabu attended several meetings at the Trident Hotel between November 2003 and January 2004. At each of these meetings, Sabu and other hopeful Indian workers were promised employment with a reputable U. S. company and a green card in exchange for the payment of approximately $8,250 in "recruitment fees," to be paid in three installments of $2,750. Sabu was also told at these meetings that he would need to take and pass a practical skills test.
40. Prior to the first installment payment, Dewan demanded that Sabu deliver $25,000 rupees (approximately $425) to Dewan's associate, "Salimon," to apply for the position with the U.S. company. Relying on the promise of work in the United States and a green card, Sabu made this payment on December 26, 2003. Dewan confirmed receipt of this "advance" payment via facsimile.
41. On or about January 20 or 22, 2004, Sabu attended a meeting at the Trident Hotel where he made his first installment payment for $2,750.00 to Indo-Amerisoft. Dewan also demanded that Sabu pay to Dewan an additional 37,000 rupees (approximately $629) in cash. Sabu made each of these payments believing that he would be able to recoup these fees through the job opportunity in the United States and the opportunity to obtain permanent residence in the United States.
42. At the January 2004 meeting, Burnett and Rao also were present. Dewan acted as the interpreter for Burnett and Rao. Burnett and Rao re-confirmed the information Sabu had previously received from Dewan regarding the job opportunity, green card application, and the three installment payments.
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43. At this meeting, Sabu was told by Dewan, Rao and Burnett that the job opportunity was with Indo-Amerisoft and that the Defendants were going to obtain the green card on his behalf before he traveled to the United States to begin his employment. As an attorney, Burnett's agreement to act on Sabu's behalf, coupled with payment from Sabu for such services, established an attorney-client relationship between Burnett and Sabu and Burnett made no suggestions to the contrary.
44. Sabu was told that if he wanted to bring any family he would need to pay an additional $1,700 "family fee." Sabu did so and made this payment to Dewan after securing a loan from a local community bank.
45. In order to make the first "advance" and installment payments, Sabu initially was forced to sell some of his wife's gold jewelry. Later, he used the remaining jewelry as collateral for a loan with a 12% interest rate.
46. Sabu was told by Dewan, Burnett and Rao that it would only take six months to obtain the initial labor certification. After hearing nothing for nine months, Sabu contacted Dewan by telephone to check on the status of the certification. Dewan assured him that everything was in order and that he should not worry. All the while, his loans were accruing interest.
47. Almost two years after Sabu made the initial payments to Dewan and IndoAmerisoft, Dewan contacted Sabu in early 2006 and told him that the labor certification had been approved. The second installment payment was tied to Indo-Amerisoft and Rao's receipt of the labor certificate. In a letter dated January 26, 2006, and typewritten on IndoAmerisoft letterhead, Rao and Indo-Amerisoft offered a $100 discount on the second installment payment as a result of the delay.
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48. During the interim, Sabu had obtained steady employment as a pipefitter in Dubai. In order to make the second installment payment, Sabu had to travel from Dubai to Mumbai to make the payment. In addition, Sabu was forced to take out another loan, this time using the land and home owned by his in-laws as collateral.
49. In total, Sabu took out a loan for 3.5 lakh rupees (approximately $5,950) in order to make the installment payments for the recruitment fees.
50. On or about February 13, 2006 Sabu met with Dewan and Rao and made the second installment payment for $2,650 to Indo-Amerisoft. At this time, he also paid an additional 62,000 rupees (approximately $1,054) directly to Dewan.
51. During these meetings, Rao, Burnett and Dewan promised Sabu that he would be paid $18.00 per hour (which would be increased after three months), that the job opportunity was to work for Indo-Amerisoft, that Indo-Amerisoft would provide housing accommodations for a small fee, and, most important to Sabu and the other Indian workers, that he would be arriving in the United States with a green card that would allow him to live and work permanently in the United States.
PlaintijJ Thampy 's Initial Recruitment 52. In November of 2003, while on leave from his job in Saudi Arabia, Plaintiff Thampy saw an advertisement in an Indian newspaper from Dewan Consultants offering the opportunity to work and to obtain permanent residency in the United States. The advertisement promised wages of $5,000 per month, significantly more than Tharnpy was making at his current job for Aramco in Saudi Arabia. Thampy contacted Dewan and an initial meeting was set in December 2003. 53. On December 12, 2003, Thampy met Dewan and Dewan's associate, "Salimon," among others. Dewan explained that Thampy would be making $22 per hour and would
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receive a green card within 18 months. Dewan also told Thampy that with this visa, he would be able to bring his family with him to the United States.
54. To complete the process, Dewan told Thampy that he would have to pay three installments of $2,750 to Indo-Amerisoft (or $8,250 total), plus three installments of 75,000 rupees to Dewan (approximately $5,160 total), for a combined cost of approximately $13,410. Additionally, Thampy would have to pay 60,000 rupees (approximately $1,400) for airfare to the United States. In sum, the cost to Thampy would be approximately $14,800.
55. Dewan told Thampy that he should be ready for a subsequent meeting in January where he would be expected to pay the first installment. To raise the funds to pay the first installment, Thampy took a loan from the Bank of Borada for 1.7 lakh rupees (approximately $3,900), using the title to his land as collateral, at a 9.5% per annum interest rate.
56. The meeting was held on or about January 17, 2004, at the Trident Hotel in Cochin. Dewan and Salimon were present, as well as Burnett and Rao. Thampy paid his first installment of $2,750 to Indo-Amerisoft and 75,000 rupees to Dewan at this meeting. After making the payment, Burnett informed Thampy that the green card process would be complete within 18 months and that he would be in touch regarding next steps. As an attorney, Burnett's agreement to act on Thampy's behalf, coupled with payment from Thampy for such services, established an attorney-client relationship between Burnett and Thampy and Burnett made no suggestions to the contrary.
57. Following the January meeting, in February 2004, Thampy returned to his job with Aramco in Saudi Arabia. In the meantime, Thampy repeatedly followed-up with Dewan and Salimon to check on the progress of the green card effort. He routinely was told that his application was on the "fast track." Other than such reassurances, however, there was no apparent progress.
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58. Over a year later, in approximately June of 2005, Dewan contacted Thampy, informing him that he had "a position" and that he should return to India (from Saudi Arabia) within two months. Relying on this promise of employment, Thampy quit his job in Saudi Arabia, and returned to India in July or August of 2005. Upon his arrival, he immediately contacted Dewan, who said that there was not, in fact, a job for Thampy at this time.
59. Without employment, Plaintiff Thampy was forced to borrow funds to support himself and his family. Thampy was able to borrow 50,000 rupees (approximately $850) from a friend, but desperate for further funds, he borrowed 1.5 lakh rupees (approximately $2550) from a loan shark, known as a "blade company," charging 10% interest per month. Blade companies are different from conventional banks, operating outside the law and engaging in threatening and illegal debt collection practices. Thampy worried that if he was unable to repay the debt to the blade company that the safety of his family could be in jeopardy.
60. Faced with debts that he could not repay, and no real forthcoming employment from Dewan despite his promises, in October or November 2005 Thampy departed for Qatar where he was able to secure employment.
61. In January 2006, Dewan contacted Thampy and informed him that his labor certification had been approved and that his second installment was now due: $2,750 to IndoAmerisoft and 75,000 rupees to Dewan. Because Thampy was then working in Qatar, he sent his brother-in-law, Varghese Kannampally, to meet with Dewan, Burnett and Rao at the Trident Hotel on February 16, 2006 to pay the second Indo-Amerisoft installment of $2,750. Relying on his friendship with a manager at the Bank of Borado, Thampy borrowed 2 lakh rupees (approximately $3,400), at an interest rate of9% per annum, to pay Indo-Amerisoft.
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62. At the meeting, Burnett and Rao told Thampy's brother-in-law that they were filing the 1-140 forms and that Thampy would be going to the United States in 6-9 months. This was confirmed to Thampy by Dewan in a subsequent telephone call. Dewan also sought his second installment of 75,000 rupees, which Thampy wired to Dewan's Dubai office from Qatar, after borrowing the funds from friends.
Initial Recruitment Allegations Common to Sabu and Thampy 63. Upon information and belief, prior to hosting meetings and testing sessions that included Plaintiffs Sabu and Thampy and others, Indo-Amerisoft, Rao and the Agents conferred in late 2003 and early 2004 by phone, mail, fax or e-mail to organize, plan, and coordinate the logistics, strategy and substantive content of these meetings and testing sessions. 64. In telephone communications, in-person meetings, faxes, contracts, and other written documents transmitted by mail and/or wire in the first half of 2004, Indo-Amerisoft, Rao and/or the Agents personally and through employees, agents and/or associates, told Plaintiffs Sabu and Thampy that if they successfully passed administered skills tests and paid fees totaling approximately 5 to 8 lakh rupees (approximately $12,000 to $20,000), then Plaintiffs would be able to apply for legal permanent resident (green card) status in the United States with Indo-Amerisoft and Rao. 65. In telephone communications, in-person meetings, faxes, written contracts, and/or other written communications, transmitted, upon information and belief, by mail and/or wire, Indo-Amerisoft, Rao and/or the Agents instructed Plaintiffs that the total fees would be paid in a series of approximately three installments. 66. At informational meetings and in telephone conversations, faxes, contracts, and other written documents transmitted in late 2003 through approximately mid-2004, Indo-
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Amerisoft, Rao and/or the Agents, personally and/or through their agents, representatives, and/or employees, represented to Plaintiffs that Indo-Amerisoft and Rao were stable and reputable U.S. companies offering lawful and ample employment opportunities, and that IndoAmerisoft and Rao would obtain for Plaintiffs green cards enabling Plaintiffs to permanently and legally immigrate to the United States with their family members.
67. At informational meetings and in telephone conversations, faxes, contracts, and other written documents transmitted in late 2003 through approximately mid-2004, IndoAmerisoft, Rao and/or the Agents, personally and/or through their agents, employees and/or representatives, told Plaintiffs that the green card process, once commenced, would be completed within 18 to 24 months.
68. In such communications with Plaintiffs, Indo-Amerisoft, Rao and/or the Agents further promised to act diligently and do everything necessary to obtain green cards for Plaintiffs in the timelines stipulated.
69. The written communications and other documents provided to Plaintiffs by IndoAmerisoft, Rao and/or the Agents through the use of mail and/or wire transmissions in and around early to mid-2004, further promised that Plaintiffs would promptly receive a refund of all or nearly all of their payments if Indo-Amerisoft, Rao and/or the Agents did not succeed in securing green cards for Plaintiffs as promised.
70. Indo-Amerisoft, Rao and/or the Agents knew or should have known that they would not refund Plaintiffs' money as promised.
71. Indo-Amerisoft, Rao and/or the Agents induced Plaintiffs to agree to pay them recruitment and other fees, and incur additional related expenses, in exchange for the promise of work and legal residence in the United States without any intention to diligently pursue Plaintiffs' green card applications; knowingly misrepresented, inter alia, that the companies
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and/or entities purportedly sponsoring Plaintiffs' applications were financially solvent and had reliable and stable employment opportunities to provide Plaintiffs; that the green card applications sponsored by such companies would be valid and bona fide under U.S. immigration law; and that the applications were likely to be successfully completed and approved within the promised timelines.
72. In reasonable reliance on the explicit and repeated promises of Indo-Amerisoft, Rao and/or the Agents regarding green cards, family members' ability to immigrate to the United States, and lawful and legitimate employment opportunities in the United States, Plaintiffs undertook considerable economic, social, familial and personal sacrifices, including payment of high fees, assumption of significant interest bearing debt, loss of real and personal property, lost work opportunities, lost or unpaid wages, and addi tional legal fees.
73. When Plaintiffs contacted Dewan, and/or Indo-Amerisoft and Rao by phone, mail, or e-mail at various times between 2004 and mid-2006 to check on the progress of their green card applications, they were assured that the green card process was going forward.
74. While awaiting the processing of their green cards, Plaintiffs continued to accrue substantial interest on the funds that they had borrowed for the purpose of making the initial installment payments to Indo-Amerisoft, Rao and/or the Agents.
75. In or around January 2006, Indo-Amerisoft, Rao and/or the Agents, personally and/or through their agents, employees and/or representatives notified Plaintiffs via telephone, e-mail, or mail communications that the labor certification and paperwork required for their green card application had been approved by the U.S. government.
76. After this notification, Indo-Amerisoft, Rao and/or the Agents used wire and/or mail communications to collect the second installment payments from Plaintiffs.
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77. By spring 2006, after the 18 to 24 month processing period promised by IndoAmerisoft, Rao and/or the Agents had lapsed, Plaintiffs had still not received their green cards.
78. Unbeknownst to Plaintiffs, at that time there actually were no job opportunities at an Indo-Amerisoft facility anywhere in the United States, despite Dewan's, Burnett's and Rao's affirmative and repeated statements that the advertised opportunity for employment and permanent legal residence in the United States was with and through Indo-Amerisoft.
In the Aftermath ofHurricane Katrina, Signal Joins the Fraudulent Enterprise and Contracts to Bring Workers to the United States.
79. After the devastation caused by Hurricane Katrina in 2005, Signal was presented with both an opportunity and a challenge. 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 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.
80. In early 2006, Global approached Signal with a purported solution to its problem. At a meeting in January or February of 2006, Global 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 it could deliver first-class fitters and welders from India at no cost to Signal. Global informed Signal that it would work with local immigration attorney Burnett and India-based recruiter Dewan to bring skilled laborers 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.
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81. On April 18, 2006, Signal formally joined the Defendants' scheme, executing a document entitled "Skilled Worker Recruitment Agreement" (the "Recruitment Agreement") with 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 agreed to deliver the workers "at no cost to Signal" and further agreed that all other charges, expenses and fees associated with recruitment, transportation, and entry of the foreign workers into the United States would be paid by the workers themselves or by Global, who in tum would be reimbursed through deductions from the wages of Plaintiffs and other workers.
82. On June 19, 2006, Signal executed a power of attorney 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 Signal. The power of attorney authorized Dewan Consultants to advertise, conduct seminars and trade tests, and sign any necessary legal documentation on Signai's behalf.
83. Also in mid-2006, Signal entered into an attorney-client relationship with the Burnett Defendants to advise Signal on immigration issues pertaining to Signal's need for workers. The Burnett Defendants never disclosed this conflict of interest to Plaintiffs. Signal and the Burnett Defendants later memorialized their engagement in a written retainer agreement. Pursuant to that agreement, Signal would not be responsible for any of the Burnett Defendants' legal fees. Rather, under the terms of the agreement, the Burnett Defendants took funds from the "recruitment fees" charged to the workers to pay for the legal services provided to Signal.
84. 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
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sponsor workers on H-2B visas, which could later be extended if Signal needed more foreign labor.
85. In 2006, the Agents 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."
86. In response to these advertisements, in or about April or May of 2006, Plaintiffs Sabu and Thampy each contacted Dewan and Dewan Consultants by telephone, and attended meetings and testing sessions organized by the Agents and their employees or representatives at locations throughout India.
Defendants File Petitions for Temporary H-2B Visas, Not Green Cards 87. Defendants told Plaintiffs that Signal would sponsor them immediately for a green card to induce them to continue in the scheme to pay large fees to travel to the United States-which had the net effect of defraying nearly aU the costs Signal would have had to expend to recruit workers legitimately-and to induce them to continue in the scheme to pay the exorbitant "recruitment fees" far in excess of what would actuaUy be required to obtain H2B visas or even the promised green cards. 88. Unbeknownst to the Plaintiffs, however, Defendants never filed nor otherwise supported green card applications for Plaintiffs, or took any other steps toward assisting Plaintiffs with securing a green card, and Signal told the United States Department of Homeland Security under penalty of perjury that Signal's need for workers was temporary. 89. Written agreements between Plaintiffs, Indo-Amerisoft, Rao and/or the Agents also explicitly promised assistance in applying for and securing a green card-assistance that
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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."
90. 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.
91. To ensure that their deception remained hidden, Defendants instructed Plaintiffs not to tell United States Department of Homeland Security officials during their forthcoming H-2B visa interview that, in addition to applying for temporary worker status, Signal had promised them that it would sponsor them for a green card. As Michael 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.
92. In late May and early June of 2006, the Burnett Defendants, on behalf of Signal, filed with the Mississippi Department of Employment Security, the Texas Workforce Commission, and the United States Department of Labor by mail, electronic transmission, and/or fax the completed forms ETA 750 and attachments seeking permission to import and
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hire 590 foreign guestworkers to work for Signal under the auspices of 8 U.S.C. § 1I01(a)(l5)(H)(ii)(b), attendant regulations 8 C.F.R. § 214.2(h)(6) and 20 C.F.R. § 655.3, and associated administrative letters and/or guidance (commonly known as "the H-2B guestworker program").
93. Knowing that Signal's labor need was projected to be at least two to three years, Signal and the Burnett Defendants stated in these applications to the state workforce commissions and forms ETA 750 that Signal would employ workers from October I, 2006, to July 31, 2007. These applications were furnished with signatures by Signal executives swearing, under penalty of perjury, to the veracity of the information in these applications.
94. The H-2B guestworker program permits U.S. employers to import foreign workers on short-term temporary visas to meet labor needs when employers attest that they cannot find U.S. workers to perform the available jobs.
95. H-2B visas are non-immigrant visas, are only valid for work with the specific employer listed on the visa, and do not provide portable and/or transferable employment authorization for the visa bearer.
96. Defendant Signal stated in the ETA 750 forms that its need for H-2B guestworkers was "peak load and a one-time occurrence" and that "the temporary workers will work for the length of the prescribed dates of need, will be paid in accordance with the prevailing wage, and will return to their home country at the end of employment."
97. In the ETA 750 forms, Defendant Signal named the Burnett Defendants as its agents for the purposes of preparing and submitting these applications to import H-2B guestworkers. The Burnett Defendants prepared and submitted these applications on behalf of Signal.
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98. At the time of filing the ETA 750 fonns and attachments with the Mississippi Department of Employment Security, the Texas Workforce Commission, and the United States Department of Labor, Signal and the Burnett Defendants knew that Signal projected the labor need that it sought to fill with foreign workers to be at least two to three years.
99. Signal and the Burnett Defendants, at or around the time they filed the ETA 750 fonns in May and June 2006, repeatedly communicated by telephone, mail, e-mail, and/or fax to direct and coordinate recruitment of Indian workers to fill the anticipated H-2B guestworker jobs. Upon infonnation and belief, Signal and/or the Burnett Defendants repeatedly communicated with Dewan, Dewan Consultants, Global, Indo-Amerisoft and Rao by telephone, mail, e-mail, and/or fax to direct and coordinate recruitment of Indian workers to fill the anticipated H-2B guestworker jobs.
100. Upon infonnation and belief, in the course of telephone, fax, e-mail and/or mail communications occurring in or around Mayor June 2006, Defendant Signal authorized Dewan, Dewan Consultants, and Global to act as their agents in India and the United Arab Emirates for the purposes of recruiting Indian welders and fitters to fill the anticipated H-2B guestworker jobs at Signal operations.
101. Upon infonnation and belief, in the course of these communications, Defendant Signal further authorized Dewan, Dewan Consultants, Global, and the Burnett Defendants to represent that Signal would assume sponsorship of the pending and as-yet-unsuccessful green card applications on behalf of Plaintiffs and other Indian workers.
102. Upon infonnation and belief, in the course of these communications, Defendant Signal further authorized Dewan, Dewan Consultants, Global, and the Burnett Defendants to represent that Signal would apply for at least two to three H-2B visa extensions on behalf of
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all the Indian H-2B workers, including Plaintiffs, to allow them to remain in the United States working for Signal while the green card applications were being processed.
103. Signal authorized its Agents to make these representations even though it knew or had reason to know that such visa extensions and green card applications would not be bona fide and valid under United States immigration law. Moreover, Signal authorized its Agents to make these misrepresentations even though it did not have the intention at that time to apply for such visa extensions and/or green cards on behalf of all of the Indian H-2B workers, including Plaintiffs.
104. In July and August of 2006, the Burnett Defendants, on behalf of Signal, filed with the United States Citizenship and Immigration Service by mail, electronic transmission, and/or fax the completed 1-129 forms and attachments seeking 590 H-2B visas for Plaintiffs, among others.
105. Despite knowing that Signal's labor need was projected to be at least two to three years, in these H-2B visa applications Signal attested to a 10-month labor need running from October 1, 2006, to July 31, 2007. Signal falsely represented to the government that at the end of this 10 month period, it intended to return all H-2B beneficiaries, including Plaintiffs, back to India. The Burnett Defendants declared that the applications were all based on information of which the Burnett Defendants had knowledge, even though the Burnett Defendants believed that Signal's intentions for these workers, including Plaintiffs, exceeded ten months.
106. In these communications, the Agents falsely assured Plaintiffs that Signal would seek at least two extensions of the temporary H-2B visa with which Plaintiffs would gain admittance to the United States, and that Plaintiffs' H-2B visa would thereafter be converted to a permanent green card.
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107. Upon information and belief, Defendants communicated and consulted frequently via mail, fax, e-mail and/or telephone communications regarding the issues to be discussed and representations to be made to the worker recruits, including Plaintiffs.
108. In their communications with Plaintiffs, the Agents further failed to disclose material facts regarding the H-2B visa, including the fact that H-2B visas confer only a temporary non-immigrant status that does not allow the bearer to adjust to permanent residency status and the fact that applying for H-2B visa status is fundamentally incompatible with simultaneously applying for a green card.
109. Plaintiffs, unaware of U.S. immigration law and the temporary, nonimmigrant character of H-2B visas and desperate not to forfeit the substantial fees they had already paid, agreed, in reliance on the representations of Indo-Amerisoft, Rao and/or the Agents, to transfer their green card applications from Indo-Amerisoft's to Signal's sponsorship and further agreed to work for Signal under an H-2B visa pursuant to the terms explained by these Defendants.
110. In reasonable reliance on the representations of Defendants, Plaintiffs entered the United States on an H-2B guest worker visas on November 28, 2006, for the purposes of working for Signal at its Pascagoula, Mississippi facility.
111. Plaintiffs would not have paid the extraordinary fees (or incurred such crushingly high, and in some instances, usurious interest) charged by Dewan, Dewan Consultants, Global, Pol, the Burnett Defendants, Indo-Amerisoft, and Rao for travel, a green card, visa, and work opportunities, had they known that these Defendants' promises and representations were false.
112. Plaintiffs would not have paid the extraordinary fees charged by Indo-Amerisoft, Rao and/or the Agents for travel, a green card, visa, and employment opportunities, had they
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known that these Defendants had failed to disclose material facts concerning the nature and terms and conditions of the immigration and work opportunities offered.
Preparations and Departurefor the United States 113.At various times during the spring, summer, and fall 2006, employees of Defendant Signal traveled to various locations in India and the United Arab Emirates and tested the worker recruits', including Plaintiffs' welding and pipefitting skills, in anticipation of employing them in the United States. 114. Plaintiffs paid costs necessary to travel to the cities where these tests were administered. 115. Plaintiffs paid admission fees charged to take these tests. 116. Plaintiffs attended and passed these tests, which were overseen and graded by Defendant Signal's and/or Defendant Dewan's agents, employees, and/or representatives. 117. Upon information and belief, prior to attending these meetings and testing sessions, Defendants Signal, Dewan, Dewan Consultants, Global, and the Burnett Defendants conferred in spring, summer, and fall 2006 by phone, mail, fax and or e-mail to organize, plan, and coordinate the logistics and substantive content of these testing sessions. 118. On or about July 20, 2006 and August 17, 2006, the United States Department of Labor approved Signal's labor certification applications for 590 H-2B workers for the period of October 1, 2006 through July 31, 2007. 119.In approving these labor certification applications, the United States Department of Labor relied on the accuracy of the applications' stated 1O-month period of labor need. 120. Upon information and belief, the Department of Labor is prohibited by its internal guidelines to grant labor certification applications without relying on the application's statement of temporary labor need.
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12l.In late August and early September 2006, the United States Citizenship and Immigration Service approved Signal's H-2B visa petitions for 590 H-2B workers, including Plaintiffs, for the period of October 1, 2006 through July 31, 2007.
122. In approving these visa petitions, the United States Citizenship and Immigration Service relied on the accuracy of the petitions' stated 10-month period of labor need and the representation that Signal's need was based on a one time peak-load temporary demand.
123. The United States Citizenship and Immigration Service must, according to regulation, rely on the stated period of the petitioner's labor need. See 8 C.F.R.214.2(h)(6)(ii)(B) (2006).
124. Defendants knew that the stated period of need in Signal's applications for labor certifications and for H-2B visas were inconsistent with Signal's projected actual labor need and therefore Defendants knew these statements to the government were false.
125. Defendants used the H-2B visas, obtained from the U.S. Government on the basis of false statements by Signal and the Burnett Defendants, to elicit payments of the third installment from Plaintiffs and other Indian workers.
126. Plaintiffs entered the United States on an H-2B guestworker visa, issued by the U.S. Government on the basis of false statements by Signal and the Burnett Defendants, on November 28, 2006, for the purposes of working for Signal at its Pascagoula facility.
127.Around the time of United States Citizenship and Immigration Service's visa approval, Plaintiffs made necessary preparations to travel to the United States on an H-2B visa to work for Signal, including: paying to obtain necessary travel and legal documents; making payments to the United States consulate, Dewan, Dewan Consultants, Global, Pol, Burnett, Indo-Amerisoft and Rao for mandatory H-2B visa and consular processing fees; attending H-
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2B visa interviews; and paying Dewan, Dewan Consultants, Global and Pol for travel arrangements.
128. In order to secure an H-2B visa to work for Signal, Plaintiffs were required to be interviewed by the United States Consular offices.
129. This consular interview required that Plaintiffs pay the costs of travel from their home or current place of employment to Madras (Chennai).
130. Defendants required that Plaintiffs sign documents permitting Dewan to receive their visa-stamped passport from the Consulate on Plaintiffs' behalf.
131. During Plaintiffs' consular interviews, the consular officials took Plaintiffs' passports from them.
132. Once Plaintiffs' visas were approved, consular officials sent the passports with H-2B visa affixed, directly to Dewan.
133. Before Plaintiffs could leave for the United States, however, Plaintiffs were required to attend final meetings in Dewan's Mumbai (Bombay) office to make the third installment payments.
134. The meeting took place mere hours before Plaintiffs' scheduled departure to the United States.
135. At these meetings, Dewan, Dewan Consultants, Global, Pol and Burnett collected the final installment payment.
136. Dewan, Dewan Consultants, Global, Pol and Burnett also required that Plaintiffs, who did not proficiently read or speak English, sign English language documents with little or no time for review.
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137. Dewan refused to return Plaintiffs' passports-which had been in Dewan's possession since after Plaintiffs' H-2B visas were approved by Consular Officials-until after Plaintiffs had paid the final installments and signed the mandatory paperwork.
138. Notably, it was only at this time that Plaintiffs learned that they would be travelling on a temporary, H-2B visa and not with the promised green card. When Plaintiff Sabu questioned Dewan about this discrepancy, Dewan assured him that Signal was working to process their green cards and that, in any event, the H-2B visa could be extended twice. Dewan had also assured Plaintiff Thampy that Signal was working to process their green cards.
139. Highly indebted and scared for their family's livelihood if they did not proceed with the job at Signal's operations, Plaintiffs grudgingly went along with this change in the immigration status on the premise that, as promised by Dewan and Burnett, Signal was indeed moving forward and working towards securing the promised green cards.
140. On November 22, 2006 Sabu made the final installment payment for $2,750.00 just hours before getting on a plane to come to the United States. Sabu was also required to pay $740 directly to Burnett and $2,490 directly to Pol (in addition to the third installment payment). In order to make these final payments, Sabu had to take out an additional loan at an interest rate that exceeded 12% per annum.
141. Plaintiff Thampy similarly was required to make the third installment payment of $2,750 just hours before departing to the United States and forced to sign numerous documents written in English which were never translated or whose contents were never explained to him.
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142. In forceful tones, Dewan, Dewan Consultants, Global, Pol, Burnett or their staff demanded that Plaintiffs quickly sign the mandatory documents, lest they miss the flights to the United States.
143. Plaintiffs had no reasonable opportunity to reVIew, negotiate, or make any changes to the documents presented them.
144. Pursuant to Defendant Signal's instructions and arrangements, approximately 300 workers, including Plaintiffs, were sent to Signal's Pascagoula facility upon arrival in the United States.
145. Plaintiffs had no choice but to pay the fees that Defendants charged to secure employment at Signal's operations.
Conditions at the Signal Facilities in Pascagoula 146. Upon arrival at Defendant Signal's facilities in Pascagoula, Plaintiffs were shocked to discover that they were expected to live in an isolated, overcrowded labor camp comprised of trailer-like bunkhouses. 147. Defendant Signal's labor camps were located in isolated, industrial areas miles removed from shopping areas, places of worship, and residential communities. These "man camps" were enclosed by fences and accessible only by a single guarded entrance. 148. The labor camp gates were constantly monitored by security guards retained by Defendant Signal. Upon information and belief, some or all of these guards may have been obtained by Signal through the Swetman Security Company. 149. Signal's security guards monitored Plaintiffs' comings and goings by requiring them to show their employee identification badge and recording when Plaintiffs entered and exited the camp. Signal's security guards also searched Plaintiffs' packages and bags when they entered the camp.
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150. Except on rare occasions, Plaintiffs were not permitted to receive visitors in the labor camp.
lSI. Up to twenty-four men were housed in each bunkhouse and made to sleep in twotiered bunk beds. The bunk beds were so tightly packed in the bunkhouses that it was difficult for Plaintiffs to move about in the narrow passageways between bunks.
152. The Signal labor camp bunkhouses had insufficient toileting and bathing facilities for twenty-four men, resulting in long lines for the bathrooms before and after work shifts.
153. Privacy was non-existent, and Plaintiffs often experienced extreme difficulty sleeping due to the constant noise resulting from the close quarters and the comings and goings of workers who worked on different shifts.
154. Defendant Signal's personnel and/or security guards conducted surprise searches of the dormitory areas of the bunkhouses, including searches of Plaintiffs' personal belongings.
ISS. Plaintiffs ate meals in Defendant Signal's mess halls, which were only open during limited hours. Due to unhygienic kitchen conditions and rotten food, workers frequently became ill, sometimes requiring hospitalization.
156. Upon information and belief, neither Defendant Signal nor Global obtained the required permit(s) to furnish the board at the Mississippi camp, and the condition and sanitation of the board further violated federal, state, and/or local law including, inter alia, the U.S. Food and Drug Administration Food Code, as adopted and modified by Mississippi Department of Health Food Regulations.
157. To add further insult to these unsanitary conditions, Defendants Signal and Global deducted labor camp fees of approximately $35 per day ($245 per week, or
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approximately $1,050 per month) from Plaintiffs' paychecks for these accommodations and meals.
158. When workers complained and asked to live outside the labor camps, Defendant Signal initially refused and subsequently told workers that if they tried to live outside the camps it still would deduct the labor camp fees from their wages. As a result of these economic realities (combined with the loans already taken out by Plaintiffs), Plaintiffs reasonably felt that they had no choice but to continue living in the Signal camps.
159. Within a few days of Plaintiffs' and other Indian H-2B workers' arrival at Signal's labor camps on November 28, 2006, Signal personnel had conducted meetings at the labor camps between Plaintiffs and representatives from specific banks. In Pascagoula, these meetings were with representatives from M & M Bank.
160. At the instruction of Defendant Signal, Plaintiffs opened accounts with the designated bank and agreed to directly deposit their wages into these accounts. Defendant Signal's establishment of Plaintiffs' accounts with this bank gave it unique access to and control over Plaintiffs' funds.
161. Signal employees, management and executives supervising the Pascagoula 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 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. '"
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162. Defendant Signal only housed Indian H-2B workers such as Plaintiffs in its labor camps. Upon infonnation and belief, workers of non-Indian descent were neither required nor allowed to live in and/or pay for accommodations in Defendant Signal's labor camps.
163. Defendant Signal subjected Indian H-2B workers such as Plaintiffs to skills testing and re-testing, on-the-job discipline, layoffs, periods without work, lack of safety precautions, unfavorable job assignments, evaluation processes, and other adverse employment actions to which non-Indian and U.S. citizen workers were not similarly subjected.
164. In addition, Signal camp personnel and supervisors frequently used offensive language in speaking with and/or referring to Plaintiffs and other Indian H-2B workers and regularly insulted Plaintiffs and other Indian H-2B workers on the basis of their race, national origin, and/or alienage.
165. During the first week of employing Plaintiffs in the United States, Defendant Signal did not reimburse Plaintiffs for any of the expenses that Plaintiffs were required to incur as a pre-condition of seeking employment with Signal.
166. During the first two weeks of employing Plaintiffs, Defendant Signal deducted approximately $100 to $200 each week from Plaintiffs' checks for job-related tool kits.
167. Conditions were so poor at Signal's Pascagoula facility that, within one month of being at the camp, Plaintiff Thampy complained to the camp manager, John Sanders, about the "jail-like" conditions of the accommodations. Plaintiff Sabu similarly complained to Signal staff about the poor and rotten food and the deplorable living conditions. Despite the support of several additional workers, their pleas were ignored.
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168. Signal personnel and management regularly threatened Plaintiffs and other H-2B workers that ifthey did not continue working for Signal, or did not work according to Signal's specifications, Plaintiffs and other Indian H-2B workers would be deported back to India.
169. Unable to earn enough to re-pay the loans they had assumed in their home country, returning to India at that time was simply not an option. In the isolated and guarded atmosphere of the labor camps and grappling with the crushing debt they had incurred to come to the United States, Plaintiffs reasonably felt that Signal's statements were threatening and felt forced to continue working for Signal despite terrible working and Jiving conditions. Plaintiffs were thus subject to a state of economic extortion and imprisonment occasioned by Defendants' collective actions. Leaving meant no job, no way to pay loans undertaken by themselves and family members, the forfeit of theirs and family members' collateral, and potential exposure to severe personal injury for themselves or family members at the hands of the "blade" companies in India. They had no choice but to incur the insults, racial slurs, animal-like treatment, horrible working conditions, inhumane environment, and severe emotional distress occasioned by the concerted actions of Defendants. They stayed, clinging to the repeated promises of a green card, believing that to be the only way out.
170. At regular meetings and in one-on-one or small group conversations with Signal camp personnel and management, some workers voiced complaints regarding the discriminatory treatment to which Indian H-2B workers were subject.
171. When Indian workers voiced grievances regarding housing, food, and wages, Defendant Signal's personnel warned them to stop complaining.
172. When Signal took no action in response to workers' complaints, numerous Indian H-2B workers living at the Pascagoula labor camp began meeting collectively to discuss how
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to persuade Signal to improve conditions in its labor camps, and also began meeting with third parties to discuss how best to address their concerns.
173. Defendant Signal became aware of these meetings, including meetings between workers and third parties whom Signal believed to be attorneys.
174. Defendant Signal, through its employees and/or agents, contacted the Agents to express its concerns about worker organizing efforts.
175. Upon information and belief, during these conversations Defendants reached an agreement regarding steps that they would take to discourage further worker organizing efforts and to ensure that the majority of the Indian H-2B workforce continued to work at Signal without complaint, as wen as to prevent the Indian H-2B workforce from exercising their legal rights.
176. Upon information and belief, Signal management and camp personnel conferred and plotted internally and with the private Swetman Security firm to respond to workers' organizing activities and to take actions to ensure that the majority of the Indian H-2B workforce continued to work at Signal without complaint, as well as to prevent the Indian H2B workforce from exercising their legal rights.
177. On or about March 7, 2007, Dewan caned one worker's wife at her home in India and warned her that her husband, Sabulal Vijayan, must stop making trouble at Signal.
178. Vijayan's wife informed him of this can, and Vijayan called Dewan on or about March 8, 2007. During that conversation, Dewan told Vijayan that Dewan had learned from Defendant Signal that Vijayan was organizing the workers and making trouble. Dewan told Vijayan that all the workers would be sent back to India if the organizing continued.
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179. Vijayan infonned other Indian workers, including Plaintiffs, about the calls his wife had received from Defendant Dewan, and word spread quickly through the Pascagoula camps regarding the threats against Vijayan.
180. News about the calls between Defendant Dewan, Vijayan and his wife substantially heightened the reasonable fears of Plaintiffs that if they complained about or tried to leave the discriminatory and substandard working and living conditions at Signal, Defendants would retaliate against Plaintiffs or their families with acts of violence, or by arranging for Plaintiffs' deportation to India.
.181. Defendant Signal called a workforce-wide meeting on or about March 8, 2007 in the Pascagoula camp, attended by Signal management and Defendant Burnett.
182. At this meeting, Signal management told Plaintiffs and other H-2B workers that Signal would fight back against organizing efforts by the workers.
183. Signal management further threatened that Signal would not extend Plaintiffs' and all other Indian H-2B workers' visas ifany of the workers took legal action against Signal. At that same meeting, Defendant Burnett told the workers that they were ineligible for other kinds of immigration relief and could depend only on Signal to maintain their H-2B immigration status and pursue their green card applications.
184. At or about the same time as this camp-wide meeting in Pascagoula, Signal management made the decision to tenninate and forcibly deport Vijayan, and three other Indian workers who had become the "spokesmen" for the Indian H-2B workers at the camp, and to do so by means that would make an example of them for the other Indian workers, including Plaintiffs, in order to keep the remaining workers in line.
185. Early on the morning of March 9, 2007, Signal locked the gate to the Pascagoula labor camp, thereby obstructing the sole means of direct entry to and exit from the camp.
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186. Around this same time, Signal camp coordinator Darrell Snyder, and approximately five security guards, some or all of whom were obtained through the private Swetman Security firm, swept through the bunkhouses carrying pictures of the four (4) workers who were to be forcibly deported to India.
187. Security guards began accosting workers to determine whether they were the individuals shown in the pictures.
188. Plaintiffs and other Indian H-2B workers became increasingly frightened and confused by these activities, particularly when word spread that Signal had locked the gate that served as the sole exit from the labor camp.
189. Around 5:15 AM that morning, Vijayan was walking towards the dining area. A security guard and Darrell Snyder, a Signal employee, aggressively confronted Vijayan and instructed him that he was in their custody.
190. Based on the threats made at the meeting on March 8, 2007 and Vijayan's recent phone call with Dewan, Vijayan feared what Defendant Signal might do to him. These feelings, combined with Vijayan's reasonable fear that Snyder and the security guards might physically hurt him, drove Vijayan to attempt suicide. Plaintiff Thampy assisted Vijayan into a vehicle that transported him from the labor camp to a local hospital for immediate medical attention.
191. Other workers were kept under guard in the communal "TV room" and prevented from leaving. These workers also were threatened with termination and deportation to India. These workers were detained in the TV room, under guard, from approximately 6 a.m. for several hours.
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192. Several security guards watched over these workers while they were detained. Over the course of several hours, security guards denied these workers' repeated requests to be let out of the TV room, to get something to drink, or to use the bathroom.
193. When other workers attempted to come into the TV room to talk to the three workers kept inside, the security guards pushed them back.
194. Confused and frightened, workers assembled outside the TV room to protest the treatment of the workers detained therein.
195. Around noon, Darrell Snyder and a Pascagoula police officer entered the TV room and the officer questioned why the detained workers were there. Snyder said that these workers had been fired and would be sent back to India.
196.By early afternoon on March 9, 2007, local media, religious advocates, and other individuals had gathered outside the camp gate to express their concern over the attempted suicide of Vijayan and the forced detention ofthee other workers.
197. Defendant Signal's actions on and after March 9, 2007 significantly intensified the reasonable fears of Plaintiffs that if they tried to leave Signal's employ or oppose the unlawful and coercive employment conditions at Signal, including by consulting with counsel, they faced the threat of physical restraint, detention, forced deportation, or other serious harms and/or abuses of the legal process.
198. Signal used this horrifying incident to its advantage. In a meeting with the workers days after the attempted suicide, Signal told them that if any of the Signal workers filed a lawsuit against Signal, Signal would send all of the workers back to India Plaintiffs understood this to mean that they must remain quiescent and work, lest Signal retaliate and ruin them financially.
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199.Having witnessed the events of March 9, 2007, Plaintiffs reasonably feared that they would suffer serious harm, physical restraint, and abuse of legal process if they were to leave Signal's employ. Deeply indebted, fearful, isolated, disoriented, and unfamiliar with their rights under United States law, Plaintiffs felt compelled to continue working for Signal.
200. Throughout the spring and summer of 2007, Signal personnel in the Mississippi camp held various meetings with the remaining Indian H-2B workers, including Plaintiffs, to discuss the status of their visas and green card applications.
201. Upon information and belief, during spring and summer 2007 Signal personnel conferred with their co-Defendants and co-conspirators via phone andlor e-mail to reach agreement on what should be said to workers attending the meetings.
202. Soon after March 9, 2007, Defendant Signal held a camp-wide meeting in Pascagoula. Signal personnel told the Indian H-2B workers that Signal would sponsor their green cards ifthey stayed at Signal and obeyed Signal's rules, and warned that if workers held any meetings against Signal's interests, they would be terminated.
203. During that same time period, Defendants Dewan and Burnett came to the Signal camp and again promised, in the presence of Signal personnel, that Signal, through its attorney Burnett, would make bona fide applications for green cards and obtain several H-2B visa extensions for the Indian H-2B workers who had not been terminated by Signal. Plaintiffs reasonably believed these promises.
204. In meetings and conversations in spring and summer 2007, Defendant Signal, through its agents and employees at the Pascagoula facility, continued to promise that Signal would arrange for the H-2B visa extensions and green cards originally promised to Plaintiffs when they were recruited in India.
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205. Plaintiffs' continuing dependence on Signal for their present and future immigration status their continuing high levels of indebtedness and unfamiliarity with United States law, reasonably led Plaintiffs to fear serious harm and/or abuse of the legal process if they left Signal's employ.
206. Under such circumstances, Plaintiffs reasonably felt like they had no choice but to continue working for Signal.
207. At various times relevant to Plaintiffs' claims, Defendant Signal refused to confirm whether valid H-2B visa extensions had in fact been obtained for Plaintiffs, coercing Plaintiffs to continue working for Signal in the hope that Signal would finally resolve their uncertain immigration status.
208. After working for Signal for almost one year and not having received the promised green card, Plaintiff Sabu and other Indian workers contacted Rao regarding their immigration status. In late 2007, Sabu and other workers met with Rao' s wife and an attorney, Kristie L. Bowerman, at a Super 8 Motel in Pascagoula. Sabu was told at this meeting that Rao would continue to help the workers with the processing of their green cards and 1-140 applications, but that they would need to pay additional monies to Rao and to the attorney for this work.
209. Plaintiff Sabu paid an additional $2,200 to the "Immigration Nationality Law Group" based on the representations made by Rao. On or about February 19, 2008, Rao instructed Sabu to meet him at a Wal-Mart in Pascagoula and deliver an additional $400. Rao represented to Sabu that this was another payment needed to process his visa and 1-140 application. Sabu, feeling helpless and deeply in debt, made each of these payments based on the misrepresentations of Rao and the other Defendants that this was the only way he could remain and work in the United States.
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210. After nearly a year enduring the horrid conditions in the Pascagoula facility, Plaintiff Thampy ultimately realized that Defendants' promises of permanent residency were illusory. Afraid that company managers would deport him if they knew his intentions, Plaintiff Thampy escaped the Pascagoula camp on October 7,2007, with the assistance of his fellow workers.
211. Plaintiff Sabu, however, feeling crushed under the weight of massive debt in India, felt compelled to continue working for Sigoal until he was terminated in December 2008. At that time, without any concern for the debts incurred by the Indian workers in their home country, Sigoal terminated Sabu and other Indian workers and fraudulently promised to seek another extension of their H-2B visas so that they could return and resume their employment with Signal. This of course was another false promise.
212. Since first contracting with Defendants in India, Plaintiffs have yet to receive from Defendants the green cards Defendants promised to them. Despite clear contractual provisions requiring them to do so, Defendants have refused to refund any of the moneys Plaintiffs paid to them for unsuccessful green card and visa processing.
213. Since first contracting with Defendants in India, Plaintiffs have had to seek other legal counsel to assist them in pursuing green card applications and other immigration relief, thereby incurring thousands of dollars in additional legal fees and costs which have not been reimbursed by Defendants.
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FIRST CLAIM FOR RELIEF THE TRAFFICKING VICTIMS PROTECTION ACT OF 2003 18 U.S.C. § 1589 (forced labor) and 18 U.S.C. § 1590 (trafficking with respect to peonage,
slavery, involuntary servitude, or forced labor) (All Defendants)
214.Plaintiffs re-allege and incorporate by reference each and every allegation contained in the preceding paragraphs as if fully set forth herein.
215. Plaintiffs bring these claims against all Defendants. 216. Plaintiffs are authorized to bring these claims pursuant to the civil remedies provision of the Trafficking Victims Protection Reauthorization Act of 2003, 18 U .S.C. § 1595 ("TVPA"). 217. In 2000, Congress enacted the 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. 218.According to House Report 106-939, the new forced labor statute was "intended to address the increasingly subtle methods of traffickers who place their victims in modemday 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." 219. In 2003, Congress amended the statute to permit individual victims of trafficking to bring civil claims against their traffickers.
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220. Defendants attempted to and didi subject Plaintiffs to forced labor in violation of 18 U.S.C. § 1589.
221. Defendant Signal knowingly att9mpted to and did physically restrain or threaten Plaintiffs with serious harm in order to obtaip the labor and services of Plaintiffs in violation of 18 U.S.C. § 1589(\).
222. Defendants knowingly attempt~d to and did obtain the labor and services of Plaintiffs using a scheme, plan, or pattern which, under the totality of the circumstances, was intended to coerce and did coerce Plaintiffs ito believe that they would suffer serious harm if they were to leave the employ of Defendant Signal in violation of 18 U.S.C. § 1589(2).
223. The scheme to isolate Plaintiffs, to coerce them to live in conditions causing psychological harm, and to limit their outside contacts, including 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 empl~y of Defendant Signal.
224. Defendants retaliated against, Plaintiffs for attempting to exercise their legal rights, threatened Plaintiffs with deportati(J)n and deceived Plaintiffs about the terms of their immigration status in a manner that constitutes an abuse of the legal process under 18 U. S.C. § 1589(3).
225. Defendants knowingly recruit~d, transported, harbored, provided, and/or obtained Plaintiffs so as to obtain their labor and services in violation of laws prohibiting peonage, slavery, involuntary servitude, and forced labor within the meaning of the provisions of the Trafficking Victims Protection Act, 18 U.S.C. § 1590.
226.1n violation of 18 U.S.C. § 1590, and in addition to the violations of 18 U.S.C. § 1589 set forth above, Defendants ~owingly recruited, transported, harbored and/or
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obtained the Plaintiffs for labor or services in furtherance of these Defendants' violations of
the following provisions of Title 18, Chapter 77 of the U.S. Code:
a. enticing, persuading, or inducing Plaintiffs to go on board an airliner and to go to various locations throughout India and the United States with the intent that they may be made or held in modem-day slavery, violating 18 U.S.C. § 1583;
b. knowingly and willfully holding Plaintiffs to involuntary servitude, as defined by the TVPA, 22 U.S.C. § 7102(5)(a) and (b), violating 18 U.S.C. § 1584;
c. removing, confiscating, or possessing Plaintiffs' passports and other immigration documents in the course of, or with the intent to violate 18 U.S.c. §§ 1583, 1584, 1589, and 1590, violating 18 U.S.c. § 1592(a); and
d. attempting to violate 18 U.S.C. §§ 1583, 1584, 1589, and 1590, violating 18 U.S.C. § 1594(a).
227. As a proximate result of the conduct of Defendants, Plaintiffs have suffered
injuries to their person, business, and property, and other damages.
228. Plaintiffs are entitled to recover compensatory and punitive damages III an
amount to be proven at trial, including attorneys' fees and costs.
SECOND CLAIM FOR RELIEF
RACKETEER INFLUENCED AND CORRUPT ORGANIZATIONS ACT 18 U.S.C. § 1962(c) and 18 U.S.C. § 1962(d)
(All Defendants) 229. Plaintiffs re-allege and incorporate by reference each and every allegation
contained in the preceding paragraphs as if fully set forth herein.
230. Plaintiffs' RICO Case Statement, filed concurrently herewith, is incorporated
herein by reference.
231. Plaintiffs' claims under the Racketeer Influenced and Corrupt Organizations Act,
18 U.S.C. §§ 1961-68 ("RICO"), are brought against all Defendants.
232. Each Plaintiff is a "person" with standing to sue within the meaning of 18 U.S.C.
§ 1964(c). 45

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233. Each Defendant is a "RICO person" within the meaning of 18 U.S.c. § 1963(1). 234. All Defendants and the United States Consular officers in India constitute an association-in-fact enterprise within the meaning of 18 U.S.c. § 1964(4) ("RICO Enterprise I"). 235. Dewan, Dewan Consultants, Global, Pol, the Burnett Defendants, and Signal constitute an association-in-fact enterprise within the meaning of 18 U.S.c. § 1964(4) ("RICO Enterprise II"). 236. Dewan, Dewan Consultants, Global, Pol, Defendant Signal, the Burnett Defendants, Swetman Security, and M & M Bank constitute an association-in-fact enterprise within the meaning of 18 U.S.C. § 1964(4) ("RICO Enterprise III").
The RICO Enterprises RICO Enterprise I
237. RICO Enterprise I is an ongoing business relationship between all Defendants and the United States Consular officers in India, with the common purpose of recruiting, transporting, providing, processing, and obtaining foreign workers to work on shipyards in the United States, including on Signal's operations in Texas and Mississippi.
238. RICO Enterprise I is engaged in interstate commerce in that its activities and transactions relating to the international and interstate movement of workers affect interstate commerce and frequently require travel and communications across state and international lines.
239. The members of RICO Enterprise I function as a continuing unit. 240. Defendants conducted or participated in, and/or conspired to conduct or participate in, the affairs of RICO Enterprise I through a pattern of numerous acts of racketeering activity in violation of 18 U.S.C. § 1962(c) and 18 U.S.c. § 1962(d), related by
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their common goal to recruit, obtain, transport, process, and provide workers through the use of fraudulent promises, exorbitant fees, forced labor, and/or trafficking.
241. Defendants conducted or participated in and/or conspired to conduct the affairs of RICO Enterprise I by engaging in the following predicate acts of racketeering activity under 18 U.S.C. § 1961(1):
a. Enticement into modem day slavery in violation of 18 U.S.c. § 1583; b. Involuntary servitude in violation of 18 U.S.C. § 1584; c. Forced labor in violation of 18 U.S.C. § 1589; d. Trafficking persons with respect to modem day slavery, involuntary
servitude, and forced labor in violation of 18 U.S.C § 1590; e. Unlawful document-related practices in furtherance of trafficking in
violation of 18 U.S.C § 1592(a); f. Mail fraud to further their unlawful scheme in violation of 18 U.S.C.
§ 1341; g. Wire fraud to further their unlawful scheme in violation of 18 U. S.C.
§ 1343; and h. Immigration document fraud in violation of 18 U.S.C. § 1546.
RICO Enterprise II 242.RICO Enterprise II is an ongoing business relationship between Dewan, Dewan Consultants, Global, Pol, the Burnett Defendants, and Signal with the common purpose of selling United States green cards, visas, and work opportunities to Indian workers to convince such workers to pay fees and to travel to the United States to work for companies, including Signa\. 243. The members of RICO Enterprise II operate as a continuing unit. 244. RICO Enterprise II is engaged in interstate commerce in that its activities and transactions relating to the sale of United States green cards, visas, and job opportunities affect interstate commerce.
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245. Dewan, Dewan Consultants, Global, Pol, the Burnett Defendants, and Signal

conducted or participated in, and/or conspired to conduct or participate in, the affairs of RICO

Enterprise II through a pattern of numerous acts of racketeering activity in violation of 18

U.S.C. § 1962(c) and 18 U.S.C. § 1962(d), related by their common goal to sell United States

green cards and work opportunities to Indian workers for the purposes of furnishing such

workers for employment at Signal's operations.

246. Dewan, Dewan Consultants, Global, Pol, the Burnett Defendants, and Signal

conducted or participated in the affairs of RICO Enterprise II by engaging in the following

predicate acts of racketeering activity under 18 U.S.C. § 1961(1):

a

Enticement into modem day slavery in violation of 18 U.S.C. § 1583;

b. Involuntary servitude in violation of 18 U.S.C. § 1584;

c. Forced labor in violation of 18 U.S.c. § 1589;

d. Trafficking persons with respect to modem day slavery, involuntary servitude, and forced labor in violation of 18 U.S.C § 1590;

e. Unlawful document-related practices in furtherance of trafficking in violation of18 U.S.C § 1592(a);

f. Mail fraud in violation of 18 U.S.C. § 1341;

g. Wire fraud in violation of 18 U.S.C. § 1343; and

h. Immigration document fraud in violation of 18 U.S.C. § 1546.

RICO Enterprise III 247. RICO Enterprise III is an ongoing business relationship between Dewan, Dewan

Consultants, Global, Pol, the Burnett Defendants, Signal, Swetman Security, and M&M Bank

with the common purpose of providing and maintaining a consistent and acquiescent labor

force at Signal operations.

248. RICO Enterprise III is engaged in interstate commerce in that its activities and

transactions relating to maintaining and providing a consistent labor force at Signal occurred 48

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across state and international lines, and involve wages and working conditions at an employer engaged in interstate commerce (Signal).
249. The members of RICO Enterprise III function as a continuing unit. 250. Dewan, Dewan Consultants, Global, Pol, the Burnett Defendants, and Signal conducted or participated in, and/or conspired to conduct or participate in, the affairs of RICO Enterprise III through a pattern of numerous acts of racketeering activity in violation of 18 U.S.C. § 1962(c) and 18 U.S.C. § 1962(d), related by their common goal to maintain a consistent and acquiescent H-2B Indian labor force at Signal through the use of fraudulent promises, forced labor, and trafficking. 251.Dewan, Dewan Consultants, Global, Pol, the Burnett Defendants, and Signal conducted or participated in, and/or conspired to conduct or participate in, the affairs of RICO Enterprise III by engaging in the following predicate acts of racketeering activity under 18 U.S.C. § 1961(1): a. Enticement into modem day slavery in violation of 18 U.S.C. § 1583; b. Involuntary servitude in violation of 18 U.S.C. § 1584; c. Forced labor in violation of 18 U.S.C. § 1589; d. Trafficking persons with respect to modem day slavery, involuntary
servitude, and forced labor in violation of 18 U.S. C § 1590; e. Unlawful document-related practices in furtherance of trafficking in
violation of 18 U.S.C § 1592(a); f. Mail fraud to further their unlawful scheme in violation of 18 U.S.C.
§ 1341; g. Wire fraud to further their unlawful scheme in violation of 18 U.S.C.
§ 1343; and h. Immigration document fraud in violation of 18 U.S.C. § 1546.
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Predicate Acts Enticement into Slavery: 18 U.S.c. § 1583 252. Signal, Global. Pol, Indo-Amerisoft, Rao, Dewan, Dewan Consultants, and the Burnett Defendants, through Enterprises I, II, or III, willfully, knowingly, and intentionally conunitted andlor conspired to commit mUltiple predicate acts of enticement into modem-day slavery in violation of 18 U.S.C. § 1583, and as set forth in Plaintiffs' First Claim for Relief. Involuntary Servitude: 18 U.S.C. § 1584 253. Signal, Global, Pol, lndo-Amerisoft, Rao, Dewan, Dewan Consultants, and the Burnett Defendants, through Enterprises J, II, or III, willfully, knowingly, and intentionally conunitted and/or conspired to conunit multiple predicate acts of involuntary servitude in violation of 18 U.S.C. § 1584, and as set forth in Plaintiffs' First Claim for Relief.
Forced Labor: 18 U.S.c. § 1589 254. Signal, Global, Pol, Indo-Amerisoft, Rao, Dewan, Dewan Consultants, and the Burnett Defendants, through Enterprises I, II, or III, willfully, knowingly, and intentionally conunitted andlor conspired to commit multiple predicate acts of forced labor in violation of 18 U.S.C. § 1589, and as set forth in Plaintiffs' First Claim for Relief.
Trafficking for the Purposes of Forced Labor and/or Involuntary Servitude: 18 U.S.C. § 1590 255. Signal, Global, Pol, Indo-Amerisoft, Rao, Dewan, Dewan Consultants, and the Burnett Defendants, through Enterprises I, II, or III, willfully, knowingly, and intentionally committed andlor conspired to commit multiple predicate acts of trafficking for the purposes offorced labor and/or involuntary servitude in violation of 18 U.S.C. § 1590, and as set forth in Plaintiffs' First Claim for Relief.
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Document Servitude: 18 U.S.C. § 1592 256. Signal, Global, Pol, Indo-Amerisoft, Rao, Dewan, Dewan Consultants, and the Burnett Defendants, through Enterprises I, II, or III willfully, knowingly, and intentionally committed and/or conspired to commit multiple predicate acts of document servitude in violation of 18 U.S.C. § 1592, and as set forth in Plaintiffs' First Claim for Relief.
Mail and Wire Fraud: 18 U.S.c. §§ 1341 and 1343 257.Defendants, through RICO Enterprise I, made and/or conspired to make false promises regarding green cards and other benefits in a scheme calculated to defraud Plaintiffs out of large sums of money. 258. Signal, Global, Pol, Indo-Amerisoft, Rao, Dewan, Dewan Consultants, and the Burnett Defendants, through Enterprises I, II, or III, made and/or conspired to make false statements related to applications submitted to the U.S. Government for H-2B visas and false promises to Plaintiffs regarding green cards and other benefits in a scheme calculated to defraud Plaintiffs out oflarge sums of money. 259. Defendants, through RICO Enterprise I, used the mails and wire communications, including communications via telephone, fax, internet and/or e-mail, on numerous occasions to further these fraudulent schemes. 260. Signal, Global, Pol, Indo-Amerisoft, Rao, Dewan, Dewan Consultants, and the Burnett Defendants, through Enterprises I, II, or III, used the mails and wire communications, including communications via telephone, fax, internet and/or e-mail on numerous occasions to further this fraudulent scheme. 261. These willful, knowing, and intentional acts constitutemail and wire fraud in violation of18 U.S.C. §§ 1341 and 1343.
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Immigration Document Fraud: 18 U.S.c. § 1546(a) 262. Defendants, through RICO Enterprise I, fraudulently sold and/or conspired to sell H-2B visa extensions and green cards to Plaintiffs despite Defendants' awareness that applications for these H-2B visa extensions and green cards were not bona fide or lawful under United States immigration law. 263. Defendants, through Enterprises I, II, or III, obtained, accepted, and/or received a 1-1-213 visa despite knowing this visa to have been procured through false statements and/or fraud on the U.S. Government. 264. Defendants Dewan, Dewan Consultants, Global, Pol, the Burnett Defendants, and Signal, through RICO Enterprises I, II, and III, fraudulently sold and/or conspired to sell H2B visa extensions and green cards to Plaintiffs despite Defendants' awareness that applications for these H-2B visa extensions and green cards were not bona fide or lawful under United States immigration law. 265. These willful, knowing, and intentional acts constitute immigration document fraud in violation of 18 U.S.C. § 1546(a).
Pattern of Related Racketeering Acts 266. Defendants engaged in the racketeering activity described herein repeatedly starting in 2003 and continuing at least through January 2009 with respect to approximately 590 Indian workers. 267. Upon information and belief, Signal sought new Indian H-2B workers for employment at Signal who may be subject to similar racketeering activities. 268. Defendants, though the RICO enterprises, rely on the racketeering acts described in this Complaint to conduct their regular business activities.
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269.Defendants' racketeering acts have or had similar purposes: to profit from the fraudulent recruitment and forced labor of Plaintiffs and otber Indian workers, and to recruit, obtain, provide and maintain a consistent, submissive, and compliant Indian H-2B guestworker labor force at Signal's operations.
270. Defendants' acts yielded similar results and caused similar injuries to Plaintiffs, including payment of high fees, assumption of significant interest bearing debt, loss of real and personal property, lost work opportunities, lost or unpaid wages, and additional legal fees.
271. As set forth in the preceding paragraphs and Exhibit I, tbe racketeering acts have or had similar participants.
272. As set forth in tbe preceding paragraphs and in Exhibit I, Defendants, tbough tbe RICO enterprises, directed tbeir racketeering activities at similar victims: Indian workers who contacted Dewan and Dewan Consultants in search of green cards, economic opportunity, and stable employment in the United States.
273. Defendants' acts have or had similar metbods of commission, such as common recruitment tactics, relatively consistent practices witb respect to collecting payments from Plaintiffs and other Indian workers, and use of similar employment practices and policies with respect to Plaintiffs and other Indian workers.
Injury 274. As a direct and proximate result of Defendants' willful, knowing, and intentional acts discussed in this section, Plaintiffs have suffered injuries to their property and/or business, including but not limited to: exorbitant fees paid by Plaintiffs for a green card, visa and otber immigration and recruitment-related services; interest on debts assumed by Plaintiffs to pay such fees; losses of personal and real property incurred in reliance on
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Defendants' fraudulent acts; lost and unpaid wages, lost employment opportunities, and other pecuniary and/or losses to real or personal property.
275. Plaintiffs are entitled to an award of damages in an amount to be determined at trial, including treble damages and attorneys' fees and costs.
THIRD CLAIM FOR RELIEF VIOLATIONS OF THE CIVIL RIGHTS ACT OF 1866
42 U.S.C. § 1981 (Discriminatory Treatment) (Signal)
276. Plaintiffs re-allege and incorporate by reference each and every allegation contained in the preceding paragraphs as if fully set forth herein.
277. Plaintiffs assert this claim pursuant to 42 U.S.C. § 1981 for declaratory relief and damages against Defendant Signal.
278. 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 Signal.
279. Defendant Signal subjected Plaintiffs to discriminatory and offensive mandatory room and board arrangements at Signal labor camps.
280. Defendant Signal did not subject its non-Indian and/or U.S. citizen employees to the same or similar room and board arrangements.
281. Defendant Signal also imposed discriminatory job-related requirements and adverse terms and conditions of employment to which non-Indian and/or U.S. citizen employees were not similarly subject.
282. Defendant Signal maintained an objectively hostile and abusive work environment on account of Plaintiffs' race, national origin, and/or alienage through the actions
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and statements of its personnel referring to and/or directed at Plaintiffs and other Indian H-2B workers.
283. 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.
284. Plaintiffs reasonably perceived their work environment to be hostile, abusive, and discriminatory on the basis of their race, national origin, and/or alienage.
285. Defendant Signal's hostile, abusive, and discriminatory treatment of Plaintiffs was unwelcome.
286. Defendant Signal knowingly, willfully, maliciously, intentionally, and without justification acted to deprive Plaintiffs of their rights.
287. As a result of Defendant Signal's unlawful acts, Plaintiffs have suffered injury to their property and/or persons.
288. Plaintiffs seek all appropriate relief, including declaratory relief, attorneys' fees, costs of this action, and damages, including compensatory and punitive damages, in an amount to be determined at trial.
FOURTH CLAIM FOR RELIEF VIOLATIONS OF THE KU KLUX KLAN ACT OF 1871 42 U.S.C. § 1985 and the Thirteenth Amendment
(All Defendants) 289. Plaintiffs re-allege and incorporate by reference each and every allegation contained in the preceding paragraphs as if fully set forth herein. 290. Plaintiffs assert this claim pursuant to 42 U.S.C. § 1985(3) for declaratory relief and damages against all Defendants.
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291. As set forth in the preceding paragraphs and Plaintiffs' First Claim for Relief, Defendants, along with non-defendants, including Pol, the Swetman Security firm and M & M Bank, conspired, agreed, plarmed and coordinated for the purpose of depriving Plaintiffs of equal protection of their rights under the Thirteenth Amendment to the United States Constitution and its implementing and enforcing statutes (inter alia, 18 U.S.C. §§ 1589,1590) to be free from forced labor, involuntary servitude, and trafficking in persons.
292. Defendants were motivated by racial, anti-Indian, and/or anti-immigrant animus when they conspired to deprive Plaintiffs of their rights and/or acted in furtherance of a conspiracy to deprive Plaintiffs of their rights.
293. Defendants knowingly, willfully, maliciously, intentionally, and without justification plarmed and acted to deprive Plaintiffs of their rights.
294. As a result of the unlawful acts of Defendants, Plaintiffs have suffered damages. 295. Plaintiffs seek all appropriate relief, including declaratory relief, attorneys' fees, costs of this action, and damages, including compensatory and punitive damages, in an amount to be determined at trial.
FIFTH CLAIM FOR RELIEF FRAUD
(All Defendants) 296. Plaintiffs re-allege and incorporate by reference each and every allegation contained in the preceding paragraphs as if fully set forth herein. 297. As set forth in the preceding paragraphs, Defendants, individually and through their agents, employees, and/or representatives, knowingly made materially false statements and representations to Plaintiffs regarding the nature and terms and conditions of applications and opportunities for immigration status and employment in the United States.
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298. As set forth in the preceding paragraphs, Defendants knowingly failed to disclose material facts to Plaintiffs regarding the nature and terms and conditions of applications and opportunities for immigration status and employment in the United States.
299. Defendants intended that the false statements made by Defendants and/or their agents, employees, and/or representatives would induce Plaintiffs to pay the exorbitant fees requested by Dewan, Dewan Consultants, Indo-Amerisoft, Rao, Global, and/or the Burnett Defendants.
300. Defendants intended that the false statements made by Defendants and/or their agents, employees, and/or representatives would induce Plaintiffs to pay exorbitant fees to Indo-Amerisoft, Rao and/or the Agents, and to leave their homes and jobs in India and the United Arab Emirates and travel to the United States to work for Signal.
301. Plaintiffs were entitled to rely on Defendants' representations. At the time the representations were made, Plaintiffs did not know or have any reason to know that the representations were false.
302. Relying on Defendants' false representations regarding green cards and employment opportunities, Plaintiffs paid large sums of money to Indo-Amerisoft, Rao and/or the Agents.
303.Relying on Defendants' false representations regarding green cards and employment opportunities, Plaintiffs incurred substantial interest-bearing debts in order to pay recruitment, immigration-related, and travel fees charged by Defendants and their agents, employees and/or representatives.
304. Relying on Defendants' false representations regarding green cards and employment opportunities, Plaintiffs sold personal and real property and surrendered employment opportunities in India.
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305. Relying on Defendants' false representations regarding green cards and employment opportunities, Plaintiffs left their homes and jobs in India and traveled to the United States to work for Defendant Signal.
306. As a direct and proximate result of Defendants' knowing, willing, and intentional actions, statements and omissions, Plaintiffs have been injured.
307. Plaintiffs are entitled to recover compensatory and punitive damages in an amount to be proven at trial.
SIXTH CLAIM FOR RELIEF NEGLIGENT MISREPRESENTATION
(All Defendants) 308. Plaintiffs re-allege and incorporate by reference each and every allegation contained in the preceding paragraphs as if fully set forth herein. 309. As set forth in the preceding paragraphs, Defendants, individually and through their agents, employees, and/or representatives, negligently made materially false statements and representations to Plaintiffs regarding the nature and terms and conditions of applications and opportunities for immigration status and employment in the United States. 310. As set forth in the preceding paragraphs, Defendants negligently failed to disclose material facts to Plaintiffs regarding the nature and terms and conditions of applications and opportunities for immigration status and employment in the United States. 311. Defendants intended that the false or misleading statements made by Defendants and/or their agents, employees, and/or representatives would induce Plaintiffs to pay the exorbitant fees requested by Indo-Amerisoft, Rao and/or the Agents. 312. Defendants intended that the false or misleading statements made by Defendants and/or their agents, employees, and/or representatives would induce Plaintiffs to pay
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exorbitant fees to Indo-Amerisoft, Rao and/or the Agents, and to leave their homes and jobs in India and the United Arab Emirates and travel to the United States to work for Defendant Signal.
313. Plaintiffs were entitled to rely on Defendants' representations. At the time the representations were made, Plaintiffs did not know or have any reason to know that the representations were false.
314. In reasonable reliance on Defendants' false or negligent representations regarding green cards and employment opportunities, Plaintiffs paid large sums of money to IndoAmerisofi, Rao and/or the Agents.
315. In reasonable reliance on Defendants' false or negligent representations regarding green cards and employment opportunities, Plaintiffs incurred substantial interest-bearing debts in order to pay recruitment, immigration-related, and travel fees charged by Defendants and their agents, employees and/or representatives.
316. In reasonable reliance on Defendants' false or negligent representations regarding green cards and employment opportunities, Plaintiffs sold personal and real property and surrendered employment opportunities in India.
317. In reasonable reliance on Defendants' false or negligent representations regarding green cards and employment opportunities, Plaintiffs left their homes and jobs in India and traveled to the United States to work for Defendant Signal.
31g.As a direct and proximate result of Defendants' knowing, willing, intentional, and/or negligent actions, statements and omissions, Plaintiffs have been injured.
319. Plaintiffs are entitled to recover compensatory and punitive damages in an amount to be proven at trial.
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SEVENTH CLAIM FOR RELIEF BREACH OF CONTRACT (All Defendants)
320. Plaintiffs re-allege and incorporate by reference each and every allegation contained in the preceding paragraphs as iffully set forth herein.
321. As set forth in the preceding paragraphs, Defendants, individually and through their agents, employees and/or representatives, offered to obtain permanent residence and immigration status for Plaintiffs in the United States, as well as steady work opportunities in the Uriited States with Defendant Signal and/or Indo-Amerisoft and Rao in exchange for Plaintiffs' payment of exorbitant fees to Defendants and their employees, agents and/or representatives and agreement to work for Defendant Signal and/or Indo-Amerisoft and Rao.
322. Plaintiffs accepted Defendants' offers, paid the agreed upon fees, and performed the agreed-upon work.
323. Defendants breached their contracts with Plaintiffs by failing to comply with their binding promises regarding permanent residence and immigration status.
324. In reliance on these agreements, Plaintiffs paid large sums of money and entered into substantial debt, surrendered other employment opportunities, and incurred other financial losses.
325. As a direct, probable and foreseeable result of Defendants' breaches, Plaintiffs have suffered damages.
326. Plaintiffs are entitled to recover compensatory damages in an amount to be proven at trial.
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EIGHTH CLAIM FOR RELIEF MONEY HAD AND RECEIVED
(All Defendants) 327. Plaintiffs re-allege and incorporate by reference each and every allegation contained in the preceding paragraphs as if fully set forth herein. 328. Plaintiffs bring this claim against all Defendants. 329.As set forth in the preceding paragraphs, Defendants, individually and through their agents, employees andlor representatives, promised to assist Plaintiffs in applying for and obtaining permanent residence and immigration status for Plaintiffs in the United States, and promised Plaintiffs steady and ongoing work opportunities in the United States with Defendant Signal. 330. These promises were made in exchange for Plaintiffs' payment of fees (including recruitment, immigration application, and travel fees) to Defendants and their employees, agents andlor representatives, and in exchange for Plaintiffs' agreement to work for Signal, Indo-Amerisoft andlor Rao. 331. Plaintiffs paid the agreed upon fees and performed the agreed-upon work. 332. Defendants failed to assist in applying for and obtaining permanent residence and immigration status for Plaintiffs in the United States. 333. Accordingly, money received by Defendants from Plaintiffs, in equity and good conscience, belongs to Plaintiffs.
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NINTH CLAIM FOR RELIEF BREACH OF FIDUCIARY DUTY
(Burnett Defendants) 334. Plaintiffs re-allege and incorporate by reference each and every allegation contained in the preceding paragraphs as iffully set forth herein. 335. Plaintiffs bring this claim against the Burnett Defendants. 336. As set forth in the preceding paragraphs, the Burnett Defendants provided legal assistance to Plaintiffs in applying for and obtaining permanent residence and immigration status for Plaintiffs in the United States. This included numerous meetings between Plaintiffs and Burnett Defendants, in both India and at Signal's Pascagoula facility, discussing such efforts, correspondence between Plaintiffs and Burnett Defendants regarding such efforts, and a request for, and payment for, legal services for such efforts. 337. By providing legal services and advice on behalf of and to the Plaintiffs, the Burnett Defendants owed fiduciary duties to Plaintiffs, including duties of candor, loyalty, trust, good faith, and special confidence. 338. The Burnett Defendants breached these fiduciary duties to Plaintiffs by, inter alia, (i) knowingly making materially false statements and representations to Plaintiffs regarding the nature and terms and conditions of applications and opportunities for immigration status in the United States, (ii) failing to disclose to Plaintiffs material information regarding the nature and terms and conditions of both applications and opportunities for immigration status, and employment in the United States, (iii) undertaking non-consensual and conflicting legal representation related to the subject matter of their representation of Plaintiffs. 339.As a direct and proximate result of the Burnett Defendants' breach of their fiduciary duties to Plaintiffs, Plaintiffs have been injured.
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TENTH CLAIM FOR RELIEF BREACH OF SPECIAL/CONFIDENTIAL RELATIONSHIP
(All Defendants) 340. Plaintiffs re-allege and incorporate by reference each and every allegation contained in the preceding paragraphs as iffully set forth herein. 341. Plaintiffs bring this claim against all Defendants. 342. As set forth in the preceding paragraphs, Defendants misrepresented to Plaintiffs that they would assist Plaintiffs to apply for and obtain work-based permanent residence and immigration status in the United States, including, inter alia: (i) preparation (and mandatory "safe keeping") of certain legal documents purportedly relating to immigration and residency, (ii) arranging travel for Plaintiffs (and, if requested, their families) to the United States, (iii) establishing mandatory personal U.S. bank accounts for Plaintiffs on their behalf in the United States, (iv) arranging for and providing "mandatory" lodging in the United States, and (v) arranging for and providing mandatory food service and/or meal plans in the United States. 343. By providing these services to the Plaintiffs, Defendants had a special, confidential relationship with the Plaintiffs, owing Plaintiffs duties of good faith, candor, loyalty, trust, and fair dealing, as well as an affirmative duty to act on behalf of the plaintiffs' safety, and to protect Plaintiffs from a harm presented or created by someone other than the Defendants. Defendants breached these duties to Plaintiffs by, inter alia, (i) failing to comply with their binding promises (as set forth above); (ii) knowingly making materially false statements and representations to Plaintiffs regarding the nature and terms and conditions of both the applications and opportunities for immigration status, and employment in the United States; (iii) failing to disclose to Plaintiffs material information regarding the nature and terms and conditions of both applications and opportunities for immigration status, and employment
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in the United States; and (iv) failing to provide adequate conditions for Plaintiffs upon their arrival to the United States.
344. As a direct and proximate result of Defendants' breach of this special, confidential relationship with Plaintiffs, Plaintiffs have been injured.
PRAYER FOR RELIEF WHEREFORE, Plaintiffs request the following relief:
a. Declaratory relief; b. Compensatory damages; c. Punitive damages; d. Constructive Trust; e. Accounting of Profits; f. Treble damages as authorized by RICO, 18 U.S.c. § 1964(c); g. An award of prevailing party attorney's fees and costs; and h. Such other relief as the Court deems just and appropriate.
JURY TRIAL DEMAND Plaintiffs demand a trial by jury of all issues so triable.
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..
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Dated: ?,,/(p/<20L3
Robert B. McDuff, MS Bar No. 2532 Sibyl C. Byrd, MS Bar No. 100601 Jacob W. Howard, MS Bar No. 103256 767 N Congress St Jackson, MS 39202 Tel: 601.969.0802 Fax: 601.969.0804 Email: rbm@mcdufflaw.com Email: scb@mcdufflaw.com Email: jake@mcdufflaw.com
Anthony N. Upshaw, pro hac vice to be filed Justin B. Uhlemann, pro hac vice to be filed Jeremy Elman, pro hac vice to be filed MCDERMOTT WILL & EMERY LLP 333 Avenue ofthe Americas, Suite 4500 Miami, Florida 33131 Tel: 305.358.3500 Fax: 305.347.6500 Email: aupshaw@mwe.com Email: juhlemann@mwe.com Email: jelman@mwe.com
Steven G. Spears, pro hac vice to be filed Scott W. Clark, pro hac vice to be filed John Low, pro hac vice to be filed MCDERMOTT WILL & EMERY LLP 1000 Louisiana St., Suite 3900 Houston, Texas 77002 Tel: 713.653.1700
Fax: 713.739.7592
Email: sspears@mwe.com Email: sc1ark@mwe.com Email: jlow@mwe.com
Attorneys for Plaintiffs
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 Case 2:13-cv-06220-SM-DEK Document 2 Filed 08/07/13 Page 1 of 18

$QUTHfRN OIS~ICT OF MISSISSIPPI
FIl EO

UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF MISSISSIPPI Southern Division
SABU PUTHUKKUTTUMEL VEEDE KRISHNAKUTTY and THAMPY PUTHAM PARAMBIL EDICULA,
Plaintiffs,
vs.
SIGNAL INTERNATIONAL LLC, INDO-AMERI SOFT L.L.C., KURELLA RAO, GLOBAL RESOURCES, INC., MALVERN C. BURNETT, LAW OFFICES OF MALVERN C. BURNETT, A.P.C., GULF COAST IMMIGRATION LAW CENTER, L.L.C., SACHIN DEWAN, and DEWAN CONSULTANTS PVT. LTD. (alk/a MEDTECH CONSULTANTS),
Defendants.
----------------------------~/

AUG 072013
J T NOBLIN CLERK
DEPUTY

RICO CASE STATEMENT

Pursuant to Local Uniform Civil Rule 83.8, Plaintiffs Sabu Puthukkuttumel Veede Krishnakutty ("Sabu") and Thampy Putham Parambil Edicula ("Thampy") (collectively, "Plaintiffs") provide the following information in support of their RICO claims. Plaintiffs reserve the right to amend this Statement, and/or to change assertions stated herein after the benefit of discovery.

1. RICO Sections Under Which Plaintiffs Assert Their Claims

A. 18 U.S.C. § 1962(c) B. 18 U.S.C. § 1962(d)

2. Identity of Each Defendant and the Alleged Misconduct and Basis for Liability of Each Defendant
For ease of discussion, Plaintiffs have grouped the individual Defendants into four distinct groups according to the identical RICO claims asserted against them: (l) Signal International, LLC ("Signal"); (2) the Legal Facilitator Defendants (Defendants Malvern C. Burnett, the Law Offices of Malvern C. Burnett, and Gulf Coast Immigration Law Center); (3) the Labor Broker Defendants (Indo-Amerisoft, L.L.C., and Kurella Rao,);and (4) the Recruiter Defendants (Defendants Global Resources, Inc., Sachin Dewan, Dewan Consultants).

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A. Signal International, LLC
i. 18 U.S.c. § 1962(c)
Signal International, LLC ("Signal") violated 18 U.S.c. § 1962(c) through the conduct of enterprises engaged in a pattern of racketeering activity. Specifically, Signal substantially conducted or participated in the affairs of three separate enterprisesI through a pattern of engaging in enticement into slavery (18 U.S.C. § 1583), involuntary servitude (18 U.S.C. § 1584), forced labor (18 U.S.C. § 1589), trafficking in persons (18 U.S.C. § 1590), unlawful document-related practices in furtherance oftrafficking ("document· Servitude") (18 U.S.C. § 1592), mail fraud (18 U.S.c. § 1341), wire fraud (18 U.S.c. § 1343), and immigration document fraud (18 U.S.C. § 1546).
Signal significantly directed, instructed, determined and participated in the actions of the enterprises with respect to its recruitment of Plaintiffs and fraudulent promises of green cards, visas, and employment from at least 2006 on. Signal also directed, instructed, and determined much of the enterprises' conduct that rose to the level of inducement into slavery, involuntary servitude, forced labor, trafficking, and document servitude.
ii.18U.S.C. § 1962(d)
With respect to Enterprise I, Signal conspired with the other Defendants, and various non-defendants to conduct or participate in the affairs of the enterprise through a pattern of racketeering activity by agreeing with one or more of tile Defendants to pursue, though the enterprise, the common criminal objective of engaging in enticement into slavery (18 U.S.C. § 1583), involuntary servitude (18 U.S.C. § 1584), forced labor (18 U.S.C. § 1589), trafficking in persons (18 U.S.C. § 1590), document servitude (18 U.S.C. § 1592), mail fraud (18 U.S.C. § \341), wire fraud (18 U.S.C. § 1343), and/or immigration document fraud (18 U. S. C. § 1546). With respect to Enterprises II and III, Signal conspired with the Legal Facilitator Defendants, the Recruiter Defendants, and various non-defendants to conduct or participate in the affairs of the enterprises through a pattern of racketeering activity by agreeing with one or more of the Defendants to pursue, though the enterprises, the common criminal objective of engaging in enticement into slavery (18 U.S.c. § 1583), involuntary servitude (18 U.S.C. § 1584), forced labor (18 U.S.C. § 1589), trafficking in persons (l8U.S-C. § 1590), document servitude (\8 U.S.C. § 1592), mail fraud (18 U.S.C. § 1341), wire fraud (18 U.S.C. § \343), and/or immigration document fraud (18 U.S.C. § 1546).
B. The Legal Facilitator Defendants (Malvern c. Burnett, the Law Offices of Malvern C. Burnett, the Gulf Coast Immigration Law Center)
1 As set forth in the Complaint, the three enterprises were: the ongoing business relationship between all Defendants and the United States Consular officers in India ("RICO Enterprise I"); the ongoing business relationship between the Recruiter Defendants, the Legal Facilitator Defendants, and Defendant Signal ("RICO Enterprise II"); and the ongoing business relationship between the all the Defendants, Swetman Security, and M & M Bank ("RICO Enterprise Ill").
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i. 18 U.S.C. § 1962(c)
The Legal Facilitator Defendants violated 18 U.S.C. § 1962(c) through the conduct of an enterprise through a pattern ofracketeering activity. Specifically, the Legal Facilitator Defendants substantially conducted or participated in the affairs of the three alleged RICO enterprises through a pattern of engaging in mail fraud (18 U.S.C. § 1341), wire fraud (18 U.S.C. § 1343), and immigration document fraud (18 U.S.C. § 1546). The Legal Facilitator Defendants significantly directed, instructed, determined and participated in the actions of the enterprise with respect to legal work, promises, representations, and assurances undertaken to effectuate the recruitment of Plaintiffs and to induce Plaintiffs' reliance on fraudulent promises of green cards, visas, and employment.
ii. 18 U.S.c. § 1962(d)
With respect to Enterprise I, the Legal Facilitator Defendants conspired with the other Defendants and various non-defendants to conduct or participate in the affairs of the enterprise through a pattern of racketeering activity by agreeing with one or more of the Defendants to pursue, though the enterprise, the common criminal objective of engaging in enticement into slavery (18 U.S.C. § 1583), involuntary servitude (18 U.S.C. § 1584), forced labor (18 U.S.C. § 1589), trafficking in persons (18 U.S.C. § 1590), document servitude (18 U.S.c. § 1592),mail fraud (18 U.S.C. § 1341), wire fraud (18 U.S.c. § 1343), and/or immigration document fraud (18 U.S.c. § 1546). With respect to Enterprises II and III, the Legal Facilitator Defendants conspired with the Recruiter Defendants, Defendant Signal, and various non-defendants to conduct or participate in the affairs of the enterprises through a pattern of racketeering activity by agreeing with one or more of the Defendants to pursue, though the enterprises, the common criminal objective of engaging in enticement into slavery (18 U.S.C. § 1583), involuntary servitude (18 U.S.c. § 1584), forced labor (18 U.S.C. § 1589), trafficking in persons (18 U.S.C. § 1590), document servitude (18 U.S.C. § 1592), mail fraud (18 U.S.C. § 1341), wire fraud (18 U.S.C. § 1343), and/or immigration document fraud (18 U.S.C. § 1546).
C. The Labor Broker Defendants (Defendants Indo-Amerisoft, L.L.C., and Kurella Rao)
i. 18 U.S.c. § 1962(c)
The Labor Broker Defendants violated 18 U.S.C. § 1962(c) through the conduct of or the participation in the affairs of an enterprise through a pattern of racketeering activity. Specifically, the Labor Broker Defendants substantially conducted or participated in the affairs of RICO Enterprise I through a pattern of engaging in mail fraud (18 U.S.C. § 1341), wire fraud (18 U.S.c. § 1343), and immigration document fraud (18 U.S.c. § 1546). The Labor Broker Defendants significantly directed, instructed, determined and participated in the actions of RICO Enterprise I with respect to the promises, representations, and assurances undertaken to effectuate the recruitment of Plaintiffs and to induce Plaintiffs' reliance on fraudulent promises of green cards and employment.
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ii. 18 U;S.C. § 1962(d)
The Labor Broker Defendants conspired with the other Defendants and various nondefendants to conduct or participate in the affairs of Enterprise I through a pattern of racketeering activity by agreeing with one or more of the Defendants to pursue, though the enterprise, the common criminal objective of engaging in mail fraud (18 U.S.C. § 1341), wire fraud (18 U.S.c. § 1343), and/or immigration document fraud (18 U.S.C. § 1546).
D. The Recruiter Defendants (Global Resources, Inc., Sachin Dewan, and Dewan Consultants (a/k/a Medteeh Consultants»
i.18U.S.C. § 1962(c)
The Recruiter Defendants violated 18 U.S.c. § 1962(c) through the conduct or participation in the affairs of an enterprise through a pattern of racketeering activity. Specifically, the Recruiter Defendants substantially conducted or participated in the affairs of the three alleged RICO enterprises through a pattern of engaging in enticement into slavery (18 U.S.C. § 1583), involuntary servitude (18 U.S.C. § 1584), forced labor (18 U.S.C. § 1589), trafficking in persons (18 U.S.C. § 1590), document servitude (18 U.S.c. § 1592), mail fraud (18 U.S.C. § 1341), wire fraud (18 U.S.C. § 1343), and immigration document fraud (18 U.S.C. § 1546). The Recruiter Defendants significantly directed, instructed, determined and participated in the actions of the enterprises with respect to efforts to recruit workers, promises, representations, and assurances undertaken to effectuate the recruitment of Plaintiffs and to induce Plaintiffs' reliance on fraudulent promises of green cards, visas, and employment. The Recruiter Defendants also directed, instructed, and determined much of the enterprises' conduct that rose to the level of the trafficking, involuntary servitude, and forced labor-related offenses.
ii. 18 U.S.C. § 1962(d)
With respect to Enterprise I, the Recruiter Defendants conspired with the other Defendants and various non-defendants to conduct or participate in the affairs of the enterprise through a pattern of racketeering activity by agreeing with one or more of the Defendants to pursue, though the enterprise, the common criminal objective of engaging in enticement into slavery (18 U.S.C. § 1583), involuntary servitude (18 U.S.C. § 1584), forced labor (18 U.S.C. § 1589), trafficking in persons (18 U.S.C. § 1590), document servitude (18 U.S.C. § 1592), mail fraud (18 U.S.C. § 1341), wire fraud (18 U.S.C. § 1343), and/or immigration document fraud (18 U.S.C. § 1546).
With respect to Enterprises II and III, the Recruiter Defendants conspired with the Legal Facilitator Defendants, Defendant Signal, and various non-defendants to conduct or participate in the affairs of the enterprises through a pattern of racketeering activity by agreeing with one or more of the Defendants to pursue, though the enterprises, the common criminal objective of engaging in enticement into slavery (18 U.S.c. § 1583), involuntary servitude (18 U.S.C. § 1584), forced labor (18 U.S,c. § 1589), trafficking in persons (18 U.S.C. § 1590), document
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servitude (18 U.S.C. § 1592), mail fraud (18 U.S.c. § 1341), wire fraud (18 U.S.C. § 1343), and immigration document fraud (18 U.S.C. § 1546).
3. Alleged Wrongdoers Other than Defendants and Their Alleged Misconduct:
A. Darrell Snyder:
Snyder participated in effectuating forced labor and trafficking at Signal operations, by, inter alia, carrying out and overseeing the maintenance of coercive and abusive conditions in the Signal labor camp in Pascagoula, Mississippi.
B. Swetman Security:
Swetman assisted Defendant Signal in effectuating forced labor and trafficking at Signal operations by participating in the forced detention and attempted deportation of several Indian workers and possibly by conducting other security activities at the Pascagoula labor camp during Plaintiffs' presence. Swetman Security is expressly alleged to be part of RICO Enterprise III.
C. Frank Tipton:
Tipton participated in effectuating forced labor and trafficking at Signal operations, by, inter alia, carrying out and overseeing the maintenance of coercive and abusive conditions in the Signal labor camp in Pascagoula, Mississippi and by participating in the forced detention and attempted deportation of several Indian workers.
D. John Sanders:
Sanders participated in effectuating forced labor and trafficking at Signal operations, by, inter alia, carrying out and overseeing the maintenance of coercive and abusive conditions in the Signal labor camp in Pascagoula, Mississippi.
E. Ravi Reddy:
Reddy participated in effectuating forced labor and trafficking at Signal operations, by, inter alia, carrying out and overseeing the maintenance of coercive and abusive conditions in the Signal labor camp in Orange, Texas.
F. Manesh Dewan:
An employee andlor agent of the Recruiter Defendants, Dewan communicated Defendants' fraudulent assurances to Plaintiffs. Dewan also coordinated paperwork and collection of fees to effectuate fraud and forced labor and trafficking of Plaintiffs.
G. "Salimon": A man known as "Salimon" served as a recruiting agent for the Recruiter Defendants in India, communicating Defendants' assurances and representations in furtherance of Defendants'
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fraudulent activities. Salimon also assisted in effectuating Defendants' forced labor and trafficking of Plaintiffs by overseeing and administering paperwork and collection of fees from Plaintiffs.
H. "Rajesh":
A man known as "Rajesh" served as an administrator or office manager for the Recruiter Defendants in India, communicating Defendants' assurances and representations in furtherance of Defendants' fraudulent activities. Rajesh also assisted in effectuating Defendants' forced labor and trafficking of Plaintiffs and others by overseeing and administering paperwork and collection of fees from Plaintiffs and others.
I. M & M Bank:
At the instruction of Defendant Signal, Plaintiffs opened accounts at M & M Bank and agreed to have their wages directly deposited into these accounts. This gave Defendant Signal unique access to and control over Plaintiffs' funds. Shortly before April 10, 2007, some fellow Indian workers fled Signal's Pascagoula labor camp. M & M denied these departed workers access to their bank accounts and invalidated their A1M cards, apparently at Defendant Signal's behest. Plaintiffs learned about this incident and reasonably believed that similar action might be taken against them should they try to leave Defendant Signal's employ. M & M Bank is expressly alleged to be part of RICO Enterprise III.
1. Other Non-Defendant Management, Employees, Agents and/or Representatives of Defendants:
Other individuals whose identities are unknown at this time are believed to have participated in, facilitated and/or supported the racketeering acts at the behest of Defendants or in their capacity as Defendants' agents, employees, and/or representatives.
K. U. S. and Indian Government Officials:
Individuals employed by the U.S. or Indian government whose identities are unknown at this time may have participated in, facilitated, and/or supported the racketeering acts at the behest of Defendants. U.S. Consular Officers are expressly alleged to be part of RICO Enterprise I. (Compl. at XX). It is not currently known whether they had any knowledge of the underlying predicate acts.
4. Alleged Victims and Their Injuries:
The victim of the racketeering activities in this case are Plaintiffs, Indian citizens who were recruited by Defendants between 2003 and 2006 and who traveled and/or was transported to the United States in November 2006 under the auspices of an H-2B visa assigned to Defendant Signal. Plaintiffs have suffered significant injuries to their business and/or property as a result of Defendants' racketeering activities and conspiracies to commit racketeering activities, including: payment of fees charged by Defendants and their agents for recruitment, travel, immigration
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processing, legal services, housing, and food; interest on loans undertaken by Plaintiffs to pay fees charged by Defendants; lost and unpaid wages, and lost work and professional opportunities.

5. Pattern of Racketeering Activity:

A. Alleged Predicate Acts:

Enticement into slavery (18 U.S.c. § 1583), involuntary servitude (18 U.S.c. § 1584), forced labor (18 U.S.C. § 1589), trafficking in persons (18 U.S.C. § 1590), document servitude (18 U.S.C. § 1592), mail fraud (18 U.S.c. § 1341), wire fraud (18 U.S.C. § 1343), and immigration document fraud (18 U.S.C. § 1546).

B. Dates, Participants in, and Description of the Predicate Acts:

1.

Enticement into Slavery (18 U.S.C. § 1583)

a. Dates: Late 2003 through December 2008.

b. Participants: Defendant Signal, the Legal Facilitator Defendants, and the Recruiter Defendants. U.S. Consular Officers, Swetman Security, and M & M Bank are alleged to be part of an enterprise through which the predicate acts were committed.

c. Facts: The facts surrounding the enticement into slavery predicate act are detailed in the general allegations of the Complaint at '11'11 1- 145, which are incorporated herein by reference. In summary, the Defendants" through their respective RICO enterprises: Enticed, persuaded, or induced Plaintiffs to board an airliner and to go to various locations India, and the United States, with the intent that they may be held in modem-day slavery, as described in the TVPA, 22 U.S.c.§ 7101 (b)(I) ("trafficking in persons is a modem form of slavery, and it is the largest manifestation of slavery today").

11.

Involuntary Servitude (18 U.S.c. § 1584)

a. Dates: November 2006 through December 2008.

b. Participants: Defendant Signal, the Legal Facilitator Defendants, and the Recruiter Defendants. U.S. Consular Officers, Swetrnan Security, and M & M Bank are alleged to be part of an enterprise through which the predicate acts were committed.

c. Facts: The facts surrounding the involuntary servitude predicate act are detailed in the general allegations of the Complaint at '11'11 146- 213, which are incorporated herein by reference. In summary, the Defendants, through their respective RICO enterprises:

(1) knowingly and willfully attempted to and did physically restrain and/or threaten Plaintiffs with serious harm in order to obtain the labor and services of Plaintiffs;
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(2) knowingly and willfully attempted to and did obtain the labor and services of Plaintiffs using a scheme, plan, or pattern which, in the totality of the circumstances, was intended to coerce and did coerce Plaintiffs to believe that they would suffer serious harm if he were to leave the employ of Defendants;
(3) knowingly and willfully forced Plaintiffs to live in conditions causing psychological harm, and limited Plaintiffs' outside contacts in order to coerce Plaintiffs into believing that they would suffer serious harm if thye were to leave Defendant Signal's employ;
(4) knowingly and willfully threatened Plaintiffs with deportation and deceived Plaintiffs about their current and future immigration status in a manner that constitutes an abuse of legal process.
111. Forced Labor (18 U.S.c. § 1589)
a. Dates: November 2006 through December 2008.
b. Participants: Defendant Signal, the Legal Facilitator Defendants, and the Recruiter Defendants. U.S. Consular Officers, Swetman Security, and M & M Bank are alleged to be part of an enterprise through which the predicate acts were committed.
c. Facts: The facts surrounding the forced labor predicate act are detailed in the general allegations of the Complaint at " 146- 213, which are incorporated herein by reference. In summary, the Defendants, through their respective RICO enterprises:
(1) knowingly attempted to and did physically restrain and/or threaten Plaintiffs with serious harm in order to obtain the labor and services of Plaintiffs;
(2) knowingly attempted to and did obtain the labor and services of Plaintiffs using a scheme, plan, or pattern which, in the totality of the circumstances, was intended to coerce and did coerce Plaintiffs to believe that they would suffer serious harm ifhe were to leave the employ of Defendants;
(3) knowingly isolated Plaintiffs, forced Plaintiffs to live in conditions causing psychological harm, and limited Plaintiffs' outside contacts in order to coerce Plaintiffs into believing that they would suffer serious harm if he were to leave Defendant Signal's employ;
(4) knowingly threatened Plaintiffs with deportation and deceived Plaintiffs about the terms of their visa in a manner that constitutes an abuse of legal process.
iv. Trafficking with respect to Peonage, Slavery, Involuntary Servitude, or Forced Labor(18U.S.C. § 1590)
8

Case 2:13-cv-06220-SM-DEK Document 2 Filed 08/07/13 Page 9 of 18

a. Dates: Late 2003 through December 2008.

b. Participants: Defendant Signal, the Legal Facilitator Defendants, and the Recruiter Defendants. U.S. Consular Officers, Swetman Security, and M & M Bank are alleged to be part of an enterprise through which the predicate acts were committed.

c. Facts: The facts surrounding the trafficking predicate act are detailed in the general allegations of the Complaint at ~~ 1- 213, which are incorporated herein by reference. In summary, the Defendants, through their respective RICO enterprises:

(I) knowingly recruited, transported and/or harbored Plaintiff in
furtherance of the Defendants' violations of 18 U.S.C. § 1583, 1584, 1589, and 1592, as set forth in ~~ 5(b )(i-iii), supra, and ~~ 5(b )(v), infra.

(2) knowingly recruited, transported and/or harbored Plaintiff by: enticing, persuading, or inducing Plaintiff to go on board aircraft or to go to various locations throughout India, the United Arab Emirates and the United States with the intent that Plaintiff may be held in modem-day slavery; holding Plaintiff in involuntary servitude and forced labor; removing, confiscating, or possessing Plaintiff s passports and other immigration documents in the course of, and with the intent to violate multiple provisions of Title 18, Chapter 77 of the U.S. Code; and attempting to violate multiple provisions of Title 18, Chapter 77 of the U.S. Code.

v. Document Servitude (18 U.S.c.§ I592(a».

a. 2006.

Dates: Between approximately July 2006 and approximately November

b. Participants: Defendant Signal, the Legal Facilitator Defendants, and the Recruiter Defendants. U.S. Consular Officers are alleged to be part of an enterprise through which these predicate acts were committed.

c. Facts: The facts surrounding this predicate act are detailed in in the general allegations of the Complaint at ~~ 1- 145, which are incorporated herein by reference. In summary, these Defendants, through their respective RICO enterprises, maintained possession of Plaintiffs' passports and visa documents to assure that Plaintiffs paid exorbitant fees and boarded U.S.-bound aircraft. The recruiter Defendants threatened to destroy the passports of any worker who did not acquiesce to these Defendants' demands. The purpose of withholding the passport and visa documents was to lead Plaintiff to believe that he had no choice but to board aircraft to travel to the United States to work for Defendant Signal. Therefore, these acts occurred in the course of violations of 18 U.S.C. §§ 1583, 1590, and I 594(a), and with intent to violate 18 U.S.C. §§ 1583, 1584, 1589 and 1590.

9

Case 2:13-cv-06220-SM-DEK Document 2 Filed 08/07/13 Page 10 of 18
VI. Mail Fraud (18 U.S.c. § 1341). See ~ 5(c), infra.
vii. Wire Fraud (18 U.S.C. § 1343). See ~ 5(c), infra.
viii. Immigration Document Fraud (18 U.S.C. § 1546). See ~ 5(c), infra.
C. Fraud-Related Predicate Acts
The circumstances constituting mail fraud, wire fraud, andlor immigration document fraud, "stated with particularity," are set forth in detail in the charts attached to this Case Statement as Exhibit I.
D. Upon information and belief, there has not been a criminal conviction for violation of the above-described predicate acts.
E. Upon information and belief, there has not yet been a judgment in regard to the above-described predicate acts resulting from civil litigation.
F. These predicate acts form a "pattern of racketeering activity" because these acts occurred after the effective date of 18 U.S.C. § 1961 and within ten years of each other.
G. Relationship Between Predicate Acts and the Enterprise as Part of a Common Plan
The predicate acts are related to one another and to the enterprises as part of a common plan. The continuing frauds were committed through the enterprises as part of the same overarching scheme to defraud Plaintiff through the use of false promises that, in exchange for exorbitant fees, Plaintiff would receive a green card if he accepted employment with Defendant Signal. Ultimately, the Defendants intended the scheme to compel Plaintiff to work, and Plaintiffs did work, for Defendant Signal under conditions that violated multiple provisions of Article 18, Chapter 77 of the U.S. Code.
6. Description of the Enterprises
I. Enterprise I
A. Individuals and Entities Constituting the Entemrise: all Defendants and currently unidentified United States Consular officers in India.
B. Structure. Pumose. Roles. Function. and Course of Conduct of the Enterprise:
This information is provided in the Complaint at ~~ 237-241, which is incorporated herein by reference. Enterprise I is an association in fact between and among each of the Defendants and U.S. Consular officers in India. The Legal Facilitator Defendants, the Recruiter Defendants, and the Labor Broker Defendants worked in concert with the common purpose of securing the labor of Plaintiff and other foreign workers at Defendant Signal's operations. The
10

Case 2:13-cv-06220-SM-DEK Document 2 Filed 08/07/13 Page 11 of 18
U.S. Consular officers in India, at the request of the Defendants, participated in the process of vetting Indian workers, including Plaintiff, for employment at Defendant Signal's operations and forwarding their passports to the Recruiter Defendants.
C. None of the Defendants are employees, officers, or directors of Enterprise I.
D. Enterprise I is an "association in fact" enterprise. As set forth in subsection (ii), supra, all of the Defendants are associated with Enterprise 1.
E. The Defendants are individuals or entities separate from Enterprise 1.
F. None ofthe Defendants are the enterprise itself.
II. Enterprise II
A. Individuals and Entities Constituting the Entemrise: The Recruiter Defendants, the Legal Facilitator Defendants, and Defendant Signal.
B. Structure, Purpose, Roles. Function, and Course of Conduct of the Entemrise:
This information is provided in the Complaint at 'iI'iI 242- 246, which is incorporated
herein by reference. Enterprise II is an association in fact between and among the Recruiter Defendants, the Legal Facilitator Defendants, and Defendant Signal. The Legal Facilitator Defendants and the Recruiter Defendants worked in concert at Defendant Signal's behest with the common purpose of selling United States visas and work opportunities to Indian workers to convince these workers, including Plaintiff, to pay fees and to travel to the United States to work for companies including Signal.
C. None of the Defendants are employees, officers, or directors of Enterprise II.
D. Enterprise II is an "association in fact" enterprise. As set forth in subsection (ii), supra, the Recruiter Defendants, the Legal Facilitator Defendants, and Defendant Signal are associated with Enterprise II.
E. The Defendants are individuals or entities separate from Enterprise II.
F. None of the Defendants are the enterprise itself.
III. Enterprise III
A. Individuals and Entities Constituting the Entemrise: The Recruiter Defendants, the Legal Facilitator Defendants, Defendant Signal, Swetman Security, and M&M Bank.
B. Structure, Purpose, Roles, Function, and Course of Conduct of the Entemrise:
II

Case 2:13-cv-06220-SM-DEK Document 2 Filed 08/07/13 Page 12 of 18
This infonnation is provided in the Complaint at '\['\[ 247-251, which is incorporated herein by reference. Enterprise III is an association in fact between and among the Recruiter Defendants, the Legal Facilitator Defendants, Defendant Signal, Swetman Security, and M & M Bank. The Legal Facilitator Defendants, the Recruiter Defendants, and Defendant Signal worked in concert with the common purpose of providing and maintaining a consistent and acquiescent Indian worker labor force at Signal's operations. Swetman Security provided security services in support of Enterprise III. M & M Bank provided financial services in support of Enterprise III.
C. None of the Defendants are employees, officers, or directors of Enterprise III.
D. Enterprise III is an "association in fact" enterprise. As set forth in subsection (ii), supra, the Recruiter Defendants, the Legal Facilitator Defendants, and Defendant Signal are associated with Enterprise III.
E. The Defendants are individuals or entities separate from Enterprise III.
F. None of the Defendants are the enterprise itself.
7. Separate Nature of the Enterprise and Racketeering Activity
I. Enterprise I
The participants in this enterprise worked in concert with the common purpose of securing the labor of Plaintiffs and other foreign workers at Defendant Signal's operations. As such, the enterprise as a whole has a common link other than the racketeering activity.
II. Enterprise II
The participants in this enterprise worked in concert with the common purpose of selling United States visas and work opportunities to Indian workers, including Plaintiffs, to convince these workers to pay fees and to travel to the United States to work for companies including Signal. While the purpose of Enterprise II may violate other statutory protections, its common link - the for-profit business of selling United States visa and work opportunities to Indian citizens - is distinguishable from the racketeering activity conducted through this enterprise.
III. Enterprise III
The participants in this enterprise worked in concert with the common purpose of providing and maintaining a consistent and acquiescent Indian worker labor force at Signal's operations. The enterprise's common link - the maintenance of a workforce for Signal - is distinguishable from the racketeering activity conducted through this enterprise.
8. Relationship Between the Activities of the Enterprise and the Pattern of Racketeering
I. Enterprise I
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Case 2:13-cv-06220-SM-DEK Document 2 Filed 08/07/13 Page 13 of 18
The Defendants used the mails and wires to defraud Plaintiffs, and committed visa fraud, for the otherwise non-racketeering purpose of securing a workforce for Defendant Signal. The Defendants engaged in both fraudulent and non-racketeering activities to further this purpose. Similarly, the Recruiter Defendants, the Legal Facilitator Defendants, and Signal, in their ongoing relationship with Plaintiff, other foreign workers, and Enterprise I as a whole, committed and/or conspired to commit acts constituting the involuntary servitude, forced labor, and human trafficking-related offenses. However, not every act Defendants committed in the context of these relationships constituted an element of these crimes. Therefore, the "usual and daily activities" of this enterprise were peppered with racketeering activities, but did not solely involve racketeering activities.
II. Enterprise II
The Defendant participants in this enterprise used the mails and wires to defraud Plaintiffs and other workers, and committed visa fraud, for the otherwise non-racketeering purpose of selling United States visas and work opportunities to Indian workers to convince these workers to pay fees and to travel to the United States to work for companies including Signal. These Defendants, through the enterprise, engaged in both fraudulent and legitimate activities to further this purpose. Similarly, these Defendants, in their ongoing relationship with Plaintiffs, other workers, and Enterprise II as a whole, committed and/or conspired to commit acts comprising elements of the crimes of the involuntary servitude, forced labor, and human trafficking-related offenses. However, not every act these Defendants committed in the context of these relationships constituted an element of these crimes. Therefore, the "usual and daily activities" of this enterprise were peppered with racketeering activities, but did not solely involve racketeering activities.
III. Enterprise III
The Defendant participants in this enterprise used the mails and wires to defraud Plaintiffs and other workers, and committed visa fraud, for the otherwise non-racketeering purpose of providing and maintaining a consistent and acquiescent Indian worker labor force at Signal's operations. These Defendants, through the enterprise, engaged in both fraudulent and legitimate activities to further this purpose. Similarly, these Defendants, in their ongoing relationship with Plaintiffs, other workers, and Enterprise III as a whole, committed and/or conspired to commit acts comprising elements of the crimes of the involuntary servitude, forced labor, and human trafficking-related offenses. However, not every act these Defendants committed in the context of these relationships constituted an element these crimes. Therefore, the "usual and daily activities" of this enterprise were peppered with racketeering activities, but did not solely involve racketeering activities.
9. Benefits Received by the Enterprise from the Alleged Pattern of Racketeering Activity
The members of the enterprise enjoyed substantial financial profits from their racketeering activities. The Recruiter Defendants, the Labor Broker Defendants, and the Legal
13

Case 2:13-cv-06220-SM-DEK Document 2 Filed 08/07/13 Page 14 of 18
Facilitator Defendants, through the respective enterprises, collected significant recruitment and immigration processing fees from Plaintiff, who relied on Defendants' fraudulent promises. The Labor Broker Defendants and Signal obtained the benefits of Plaintiff who, due to his extreme level of personal indebtedness incurred in reliance on Defendants' fraud, was desperate to pay the Labor Broker Defendants for promised immigration and work opportunities and to accept and maintain employment with Defendant Signal. The unlawful document-related activities committed by the Recruiter Defendants, coupled with the involuntary servitude, forced labor, and human trafficking-related offenses committed by the Recruiter Defendants and Signal in conspiracy with the Legal Facilitator Defendants caused Plaintiff to surrender and forgo other employment and business opportunities and to remain working at Signal despite illegally low wages and large deductions for substandard and discriminatory labor camp housing. Defendant Signal profited from maintaining the forced labor of Plaintiff, Plaintiffs acquiescence to Signal's excessive deductions from his paychecks, and Signal's failure to reimburse Plaintiff for mandatory recruitment, visa, and travel expenses as required by United States minimum wage laws.
10. Describe the Effect of the Activities on Interstate Commerce
The enterprises and Defendants identified in this action have conducted the racketeering activities and other business activities relevant to this action through interstate and international travel and communications. Plaintiff has traveled and communicated across state lines and international borders in undertaking the transactions, travel, and provision of labor and services induced by Defendants' racketeering acts. Defendant Signal operates throughout the multi-state Gulf Coast region, with worksites and labor camps in Texas and Mississippi. Defendants' business and racketeering activities (involving travel, mail and wire transactions, importation of foreign workers, and payment of wages within the United States), as well as actions taken by Plaintiff in response to and/or as a result of those activities (involving travel, mail, and wire transactions, and work performed within the United States) affect interstate commerce.
11. Not applicable.
12. Not applicable.
13. The Complaint alleges a violation of 18 U.S.c. § 1962(c) and:
A. None of the Defendants were, at any relevant time, employed by any of the enterprises. All Defendants are associated with Enterprise I. The Recruiter Defendants, the Legal Facilitator Defendants, and Defendant Signal are associated with Enterprises II and III.
B. The liable Defendant "persons" are separate and distinct entities from the enterprises alleged above.
14. The Complaint alleges a violation of 18 U.S.c. § 1962(d) (Description of the Alleged Conspiracy)
Plaintiffs assert the following RICO conspiracies in this action:
14

Case 2:13-cv-06220-SM-DEK Document 2 Filed 08/07/13 Page 15 of 18
The Defendants agreed to engage in mail, wire, and immigration document fraud to recruit, transport, and obtain Plaintiffs and other Indian workers for employment at Signal's operations in Mississippi and Texas. Defendant Signal authorized the Recruiter Defendants and the Legal Facilitator Defendants to act as its agents for the purpose of fraudulently encouraging Plaintiffs to obtain an H-2B visa to come to the United States to work for SignaL The Recruiter Defendants, the Legal Facilitator Defendants, the Labor Broker Defendants, and Defendant Signal agreed to certain fraudulent communications and transactions calculated to induce Plaintiffs' reasonable reliance and convince Plaintiffs to pay large sums of money to come to the United States to work for Signal.
The Labor Recruiters, the Legal Facilitators and Defendant Signal agreed that each would undertake certain measures to ensure that Plaintiff would be enticed to travel on airliners and go to places throughout India and the United States, and would continue to work at Signal's operations, resulting in involuntary servitude, forced labor, trafficking in persons, and document servitude.
15. Relationship Between Injuries and Violations of RICO
Plaintiffs have suffered significant injuries to their business and/or property as a result of Defendants' racketeering activities including: payment of fees charged by Defendants and their agents for recruitment, travel, immigration processing, legal services, housing, and food; interest on loans undertaken by Plaintiffs to pay fees charged by Defendants; lost and unpaid wages, lost personal property abandoned at the labor camps, and lost work and professional opportunities.
All Defendants' acts of mail, wire, and visa fraud effectuated and directly induced Plaintiffs to pay exorbitant sums of money to the Recruiter Defendants, the Legal Facilitator Defendants, and the Labor Broker Defendants by promising that Plaintiffs would receive permanent immigration status for themselves and their family and lucrative work in the United States. Relying on Defendants' fraudulent promises, Plaintiffs incurred substantial interestbearing debts and sold personal and real property to obtain the funds necessary to pay the Recruiter Defendants, Legal Facilitator Defendants and Labor Broker Defendants.
Defendants' acts of inducement into slavery, involuntary servitude, document servitude, trafficking in persons, and forced labor caused Plaintiffs to make substantial payments to the Recruiter Defendants upon departing India for the United States, and caused Plaintiffs to remain working at Signal despite illegally low wages and wage deductions for housing and food at Signal's labor camps. These acts also coerced Plaintiffs to surrender and forgo other employment opportunities and to suffer emotional distress.
16. Actual Damages Sustained by Reason of RICO Violations
Damages Resulting from Defendants' Mail. Wire, and Visa Fraud:
In reliance on Defendants' fraudulent promises regarding green cards and as a result of Defendants' conspiracy to make these fraudulent representations, Plaintiffs spent an estimated
15

Case 2:13-cv-06220-SM-DEK Document 2 Filed 08/07/13 Page 16 of 18

$15,000 to $20,000 or more to pay the mandatory fees charged by the Recruiter Defendants, the Labor Broker Defendants, and the Legal Facilitator Defendants. Each Plaintiff made three separate installment payments of $2,750.00 to the Recruiter Defendants, the Labor Broker Defendants, and the Legal Facilitator Defendants. Plaintiffs were also forced to incur expenses related to transportation/travel to attend the informational meetings, attend the interview at the U.S. Consulate and the administration of the practical and written skills tests. In addition, these Defendants required that Plaintiff Sabu make an "advance" payment to "Salimon", an associate of Sachin Dewan and Dewan Consultants for 25,000 rupees. Dewan and Dewan Consultants also forced Plaintiffs to make a cash payment directly to Dewan with each installment payment for 75,000 rupees (225,000 rupees total). At the time the Plaintiffs delivered the third installment payments, Plaintiff Sabu was also forced to make separate payments to Malvern Burnett and Michal Pol for $740.00 and $2,490.00, respectively. In addition, Plaintiffs were forced to pay their own travel expenses to the United States, estimated at 48,000 to 60,000 rupees each.

Damages as a Result of Defendants' Involuntary Servitude, Forced Labor, and Human Trafficking-Related RICO Violations:

Plaintiffs suffered damages as a result of Defendants', Defendants' agents, employees and/or representatives subjecting them to and/or conspiring to subject them to enticement into slavery, involuntary servitude, forced labor, human trafficking, and document servitude. Plaintiffs' damages include, but are not limited to, the damages resulting from the fraud-related acts delineated above. Plaintiffs are also entitled to damages for rent charges and loss of work opportunities in the U.S. during and after their employment with Signal ceased. Because these damages continue to accrue, a specific amount cannot currently be calculated.

With respect to these predicate acts, the Recruiter Defendants, the Legal Facilitator Defendants, and Signal are jointly and severally liable for related damages.

All Violations:

With respect to all Defendants' RICO violations, Plaintiffs seek treble damages pursuant to 18 U,S.C § 1964(c), plus costs and attorneys' fees associated with bringing this action.

17. All Other Federal Causes of Action

A. Plaintiffs bring the following additional federal claims in this action:

1.

Trafficking Victims Protection Act of2003 (TVPA), 18 U.S.C. § 1589

H. Trafficking Victims Protection Act of 2003 (TVPA), 18 U.S.C. § 1590

HI. Civil Rights Act of 1866, 42 U.S.C § 1981

iv. Ku Klux Klan Act of 1871, 42 U.S.C § 1985

18. Pendent State Law Claims

A. Plaintiffs bring the following additional state law claims in this action:

16

Case 2:13-cv-06220-SM-DEK Document 2 Filed 08/07/13 Page 17 of 18

1.

Fraud

11. Negligent Misrepresentation

111. Breach of contract

IV. Money Had and Received

v. Breach of Fiduciary Duty

vi. Breach of Special/Confidential Relationship

19. Additional Helpful Information

Plaintiffs are not aware of any additional information which may be helpful to the Court at this time. Plaintiffs reserve the right to amend this RICO Case Statement should additional useful information come to light and as necessary.

Dated: 8i&(:2013

:rfl1tt~

Robert B. McDuff, MS Bar No. 2532 Sibyl C. Byrd, MS BarNo. 100601 Jacob W. Howard, MS Bar No. 103256 767 N Congress St Jackson, MS 39202 Tel: 601.969.0802 Fax: 601.969.0804 Email: rbm@mcduffiaw.com Email: scb@mcduffiaw.com Email: jake@mcduffiaw.com
Anthony N. Upshaw, pro hac vice to be filed Justin B. Uhlemann, pro hac vice to be filed Jeremy Elman, pro hac vice to be filed MCDERMOTT WILL & EMERY LLP 333 Avenue of the Americas, Suite 4500 Miami, Florida 33131 Tel: 305.358.3500 Fax: 305.347.6500 Email: aupshaw@mwe.com Email: juhlemann@mwe.com Email: jelman@mwe.com

17

Case 2:13-cv-06220-SM-DEK Document 2 Filed 08/07/13 Page 18 of 18 Steven G. Spears, pro hac vice to be filed Scott W. Clark, pro hac vice to be filed John Low, pro hac vice to be filed MCDERMOTT WILL & EMERY LLP 1000 Louisiana St., Suite 3900 Houston, Texas 77002 Tel: 713.653.1700 Fax: 713.739.7592 Email: sspears!@.mwe.com Email: sclark!@.mwe.com Email: jlow@mwe.com Attorneys for Plaintiffs
18

 
 Case 2:13-cv-06220-SM-DEK Document 26 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-06220-SM-DEK Document 26 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-

Case 2:13-cv-06220-SM-DEK Document 26 Filed 10/18/13 Page 3 of 10
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-

Case 2:13-cv-06220-SM-DEK Document 26 Filed 10/18/13 Page 4 of 10
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-

Case 2:13-cv-06220-SM-DEK Document 26 Filed 10/18/13 Page 5 of 10
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
-5-

Case 2:13-cv-06220-SM-DEK Document 26 Filed 10/18/13 Page 6 of 10
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.
-6-

Case 2:13-cv-06220-SM-DEK Document 26 Filed 10/18/13 Page 7 of 10
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-

Case 2:13-cv-06220-SM-DEK Document 26 Filed 10/18/13 Page 8 of 10
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.
-8-

Case 2:13-cv-06220-SM-DEK Document 26 Filed 10/18/13 Page 9 of 10
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,
-9-

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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
-10-

 
 Case 2:13-cv-06218-SM-DEK Document 183 Filed 02/17/14 Page 1 of 11

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; Chakkiyattil v. Signal, No. 13-6219; Krishnakutty v. Signal, No. 13-6220; Devassy v. Signal, No. 13-6221.
PROTECTIVE ORDER The Court issues this Protective Order (“Protective Order” or “Order”) to facilitate document disclosure and production under the Local Rules of this Court and the Federal Rules of Civil Procedure in Achari, et al. v. Signal Int’l, LLC, et al. (No. 13-6218), Chakkiyattil, et al. v. Signal Int’l, LLC, et al. (No. 13-6219), Krishnakutty, et al. v. Signal Int’l, LLC, et al. (No. 13-6220), and Devassy, et al. v. Signal Int’l, LLC, et al. (No. 13-6221) (collectively, the “Consolidated Actions”). Plaintiffs in the Consolidated Actions filed a Motion for Entry of

Case 2:13-cv-06218-SM-DEK Document 183 Filed 02/17/14 Page 2 of 11
Protective Order.1 The Court enters Plaintiffs’ proposed Protective Order, with the exception of Section A.1., and will rule on the disputed portion of Plaintiffs’ proposed Protective Order by separate order. Unless modified pursuant to the terms contained in this Order, this Order shall remain in effect through the conclusion of the Consolidated Actions.
IT IS ORDERED, DECREED, AND ADJUDGED AS FOLLOWS: A. The following general provisions shall apply to documents and information sought,
requested, or subpoenaed in the Consolidated Actions: 1. [Intentionally left blank.] 2. Any Party (“Party” or “Parties”) to the Consolidated Actions may request through discovery or subpoena any documents and information relevant to these litigations, except documents or information excluded from production pursuant to this or any other Order issued by the Court in these litigations. 3. Pursuant to the Court’s Minute Entry dated November 15, 2013 (ECF No. 108), all discovery taken in David, et al. v. Signal Int’l, LLC, et al. (No. 08-1220), EEOC v. Signal Int’l, LLC, et al. (No. 12-557) (together, the “Related Actions”), or the Consolidated Actions may be used in any of the Consolidated Actions or Related Actions. 4. No documents and information deemed to be “CONFIDENTIAL” (including those documents described in paragraph A(6) below) by the Party from whom such documents and information are sought (the “Producing Party”) is exempt from the disclosure and production requirements contained in Fed. R. Civ. P. 26, 33, or 34, including any associated disclosure and production deadlines.
1 R. Doc. 144.
2

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5. Parties shall follow Fed. R. Civ. P. 26(b)(5) for the handling of documents for which a privilege of any kind, including a trial preparation privilege, is being asserted.
6. Any Party may designate as “CONFIDENTIAL” any document or material containing information that fits into one of the following categories:
a. Documents and information properly classified as secret in the interest of national defense or foreign policy;
b. Documents and information specifically exempted from disclosure by statute, provided that such statute (i) requires that the matters be withheld from the public in such a manner as to leave no discretion on the issue, or (ii) establishes particular criteria for withholding or refers to particular types of matters to be withheld;
c. Trade secrets and commercial or financial information obtained from a person, entity or party;
d. Medical and mental health records and files about an individual, whether that person is a Party, class member, or witness; or
e. Documents and information identifying an individual’s social security number, whether that person is a Party, a current or former Party employee, class member, or witness.
7. No Producing Party may designate as “CONFIDENTIAL”: a. advertising materials; b. materials that on their face show that they have been published to the
general public; or c. documents that have been submitted to any governmental entity without
request for confidential treatment.
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8. Any Party may designate a document as “CONFIDENTIAL” by marking the document “CONFIDENTIAL” on its first page and including the letter applicable to the category next to the confidentiality marker. Parties will make efforts to mark documents “CONFIDENTIAL” as described in this paragraph, but recognizing that some documents and other evidence may not practicably be so marked, Parties may also designate evidence as “CONFIDENTIAL” pursuant to this Order by describing precisely what evidence shall be so designated in a cover page or by other clear statements.
9. All documents and information designated as “CONFIDENTIAL” shall be handled and maintained as provided for in Section B of this Order.
B. Documents and information designated “CONFIDENTIAL” shall be reviewed, handled, and maintained in the following manner:
1. Prior to designating any documents and information “CONFIDENTIAL,” the Producing Party shall review the documents and information and make a good faith determination that the documents and information contain confidential information. By designating any document and information “CONFIDENTIAL,” the Producing Party is attesting that it has conducted a good faith review of the documents and information, and is not making the designation for any improper reason.
2. The Parties, their attorneys, and their staff, shall only use documents and information marked “CONFIDENTIAL” for purposes of litigating the Consolidated Actions or the Related Actions. Disclosure occurring pursuant to the Parties’ litigation of these Actions or in accordance with the Court’s instruction to provide discovery to all counsel of record in the Consolidated Actions and Related Actions shall not constitute a violation of this Order so long as the terms of this Order are followed. Making copies, abstracts, digests and analyses of documents
4

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and information marked “CONFIDENTIAL” or preparing documents for filing shall not constitute a violation of this Order. Such copies, abstracts, digests, analyses and/or filings shall be deemed to have the same level of protection under the terms of this Order as the original discovery material marked “CONFIDENTIAL.” Nothing herein shall restrict an authorized recipient from converting or translating documents and information marked “CONFIDENTIAL” into electronic or machine-readable form for incorporation into a data retrieval system used in connection with the Consolidated Actions, provided that use of and access to such converted information, in whatever form stored or reproduced, shall be subject to the same terms and restrictions provided in this Order as is the original documents and information.
3. The Parties to the Consolidated Actions, their attorneys, and their staff, shall not give, show, or otherwise divulge any “CONFIDENTIAL” documents and information produced in the Consolidated Actions by any Party, or the substance or contents thereof, or any copies or summaries thereof, to any entity or person except:
a. the attorneys for any Party to a Consolidated Action or Related Action and such attorneys’ staffs and agents;
b. persons or entities retained by attorneys for a Party to a Consolidated Action or Related Action as consultants or expert witnesses;
c. Parties to the Consolidated Actions or Related Actions, including, to the extent that such disclosure is reasonably necessary to prosecution of these Actions, their employees, supervisors, managers, contractors, officers, directors, and alter egos;
d. the Court and its support staff; e. court reporters, deposition videographers, their transcribers, assistants, and employees;
5

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f. special masters, mediators, or other third parties appointed by the Court or retained by the Parties for resolution of settlement, discovery, or other disputes and their necessary personnel;
g. deposition witnesses and their counsel; h. potential technical experts, potential expert witnesses and potential fact witnesses involved in the preparation of this action; i. interpreters, translators, and their assistants and employees; j. any other person agreed to in writing by the Producing Party; and k. any other person to whom the Court compels disclosure of the material designated as “CONFIDENTIAL” or to whom disclosure is required by law. Unless otherwise agreed to in writing by the Producing Party or ordered by the Court, persons described in paragraphs 3(d)-(f) who have been shown material designated as “CONFIDENTIAL” shall not retain copies thereof. To the extent that a Party to whom documents are produced (“Receiving Party”) believes that “CONFIDENTIAL” documents and information should be produced, disclosed or shown to an individual and/or entity not provided for in this paragraph, the Receiving Party shall first notify the Producing Party. If the Producing Party objects to such production, disclosure, or showing, it shall notify the Receiving Party within five (5) business days of receiving notice, at which time the Receiving Party may file a motion with the Court. No production, disclosure or showing shall be made prior to the time the motion is ruled upon by the Court. If the Producing Party does not respond to the notice within five (5) business days, or notifies the Receiving Party that it does not object to the production, disclosure, or showing, the Receiving Party may disclose the documents and information at its discretion.
6

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4. Before or in conjunction with presenting “CONFIDENTIAL” documents and information to the persons listed in paragraph #3, the presenting Party shall advise the person that the confidential documents and information shall not be disclosed or disseminated except in relation to the Consolidated Actions or Related Actions, and only to individuals to whom the person must disclose or disseminate the documents and information in order to meet his or her obligations in these litigations. The method of advising the person may vary according to the circumstances but, as soon as practicable (if practicable), the Party shall present the person with a copy of this Protective Order and shall attempt to obtain the person’s signature on a complete copy of the Protective Order.
5. Any “CONFIDENTIAL” documents and information filed with the Court shall be filed in sealed envelopes or other sealed containers (or in other sealed manners as designated and approved by the Court) that shall bear the caption of this action, an indication of the nature of the contents of such envelope or container, a notation marked “CONFIDENTIAL,” and a statement substantially stating that the envelope or container is not to be opened, nor the contents thereof to be displayed or revealed, except by express order of the Court.
6. Inadvertent or unintentional production of material which is not designated “CONFIDENTIAL” shall not be deemed a waiver in whole or in part of a claim for confidential treatment. The Producing Party may notify the Receiving Party that documents and information that should have been designated as “CONFIDENTIAL” under the terms of this Order were inadvertently produced without being designated as such. Upon receiving such notice from the Producing Party, the Receiving Party shall immediately treat the documents and information as if it had been so designated. The Producing Party shall, within two (2) business days of providing such notice, produce to the Receiving Party copies of the relevant documents and information
7

Case 2:13-cv-06218-SM-DEK Document 183 Filed 02/17/14 Page 8 of 11
which are appropriately marked as “CONFIDENTIAL.” The Receiving Party shall thereafter make reasonable efforts to delete and/or destroy the incorrectly designated material and all copies thereof. No Party shall be held in violation of this Order if, before receipt of such notice, any documents and information inadvertently produced without being designated “CONFIDENTIAL” were disclosed to any person(s) not authorized to receive “CONFIDENTIAL” documents and information under this Order.
7. If the Receiving Party believes that any documents and information improperly have been designated “CONFIDENTIAL” and seeks to challenge the designation, it shall notify the Producing Party in writing of its objections and bases. The Producing Party and the Receiving Party shall work together to resolve any disputes as to “CONFIDENTIAL” documents and information prior to seeking assistance from the Court. Within five (5) business days of receipt of the written notice, the Producing Party shall seek a protective Order from the Court, or notify the Receiving Party, in writing, of its intent not to seek a protective order. The Receiving Party shall not disclose or disseminate the documents and information until expiration of the five (5) business days referenced above, receipt of notice of the Producing Party’s intent not to seek a protective order, or on the Producing Party’s filing of a motion with the Court, whichever occurs first. In the event the Producing Party files a motion, the Receiving Party will treat the documents and information as “CONFIDENTIAL” (pursuant to the terms of this Protective Order) until the Court rules upon the Producing Party’s motion. The Party seeking a protective order from the Court shall attach a copy of this Protective Order, and all written communications associated with efforts to resolve the dispute, as an exhibit to its Court filing.
8. Documents produced in the Consolidated Actions prior to the entry of this Order that have been marked “CONFIDENTIAL” shall be treated as “CONFIDENTIAL,” subject to all
8

Case 2:13-cv-06218-SM-DEK Document 183 Filed 02/17/14 Page 9 of 11
of the aforementioned provisions of this Order (including the right to challenge the confidentiality designation).
9. Nothing in this Order shall be construed to prevent a Party from waiving its own confidentiality designation(s) at any time.
10. If a Party objects on confidentiality grounds to documents and information sought pursuant to a subpoena, it shall notify the Party serving the subpoena that it believes that the documents and information are confidential, and the Party serving the subpoena shall agree to handle and maintain the documents and information consistent with the terms of this Protective Order. If the Party serving the subpoena, after receipt of the documents and information, does not believe the documents should be designated “CONFIDENTIAL,” it shall notify the objecting Party within ten (10) days after receipt of the documents and information, and the parties thereafter shall follow the process contained in this Protective Order to resolve the issue.
11. During a deposition, a Party which seeks (for the first time) to have documents and testimony treated as confidential shall make its request known on the record, triggering the obligations contained in this Protective Order.
12. To the extent that material designated as “CONFIDENTIAL” is used in depositions, such documents or information shall remain subject to the provisions of this Order, along with the transcript pages of the deposition testimony referring to the “CONFIDENTIAL” material.
13. Subject to the Federal Rules of Civil Procedure and any other applicable rules, “CONFIDENTIAL” material may be offered in evidence at trial or other court proceeding, provided that the proponent of the evidence gives notice to counsel for the Party or other person that made the “CONFIDENTIAL” material designation, sufficiently in advance so as to enable
9

Case 2:13-cv-06218-SM-DEK Document 183 Filed 02/17/14 Page 10 of 11
any Party, either in writing or in open court, to move the Court for an order that the evidence be received in camera or under other conditions to prevent unnecessary disclosures. The Court will then determine whether the proffered evidence should continue to be treated as “CONFIDENTIAL” material and, if so, what protection, if any, may be afforded to such information at the trial or other court proceeding.
14. If any party files with the Court any medical and mental health records and/or files as described in paragraph 6(d), supra, or if any party files with the Court any reference to, description of, summary of, or excerpt from any such records or files (collectively “medical records and filings”), the Clerk shall keep such medical records and filings under seal and shall make it available only to the Court and persons authorized by the terms of this Protective Order to have access thereto. The person filing any such medical records and filings shall be responsible for designating to the Clerk that the information is subject to this Protective Order and is to be kept under seal. At the conclusion of the Consolidated Actions, including any appeals, such records and filings which have been filed with the Court under seal shall be returned, upon reasonable request, to the Party which designated it as “CONFIDENTIAL.”
15. Any Producing Party may redact the first five digits of social security numbers (i.e., “xxx-xx-1234”) appearing in documents produced by that Party.
16. At the conclusion of these litigations, including any appeals, Receiving Parties shall destroy any documents or information produced to them in discovery and designated “CONFIDENTIAL” pursuant to this Order, except insofar as preservation and disclosure is mandated by court order.
C. Rule 34 of the Federal Rules of Civil Procedure shall govern the production of electronically stored information (“ESI”) in the Consolidated Actions. The parties may request
10

Case 2:13-cv-06218-SM-DEK Document 183 Filed 02/17/14 Page 11 of 11
ESI from any other party in any format or form allowed under the Rules. The protective orders entered in David, et al. v. Signal Int’l, LLC, et al. (No. 08-1220) (David Doc. #1352) or EEOC v. Signal Int’l, LLC, et al. (No. 12-557) (EEOC Doc. #285) shall have no application to the Consolidated Actions.
D. Use of the material gleaned through the pre-trial discovery process should be limited to the preparation for and use at trial and for no other purpose until this dispute is resolved, through trial or settlement.
E. All home addresses and telephone numbers of former Signal employees and/or witnesses disclosed either in discovery or Initial Disclosures shall be produced to counsel and: (1) only counsel for the Parties and persons deemed, in good faith, by counsel to be necessary to prosecution of these litigations shall be privy to this information; (2) this information will not be disseminated to any of the Parties; (3) counsel may use these addresses only in connection with prosecution of the Consolidated Actions; and (4) in the event any document containing this information is entered into the public record, the home addresses and telephone numbers for these individuals will be fully redacted.
F. Counsel for the Parties are not required to serve a subpoena on any non-party should counsel wish to speak to such a non-party.
IT IS SO ORDERED Signed in New Orleans, Louisiana, this1_7_thday of February, 2014
____________________________________ HON. SUSIE MORGAN
UNITED STATES DISTRICT JUDGE
11

 
 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.
4

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.
7

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

 
 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 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. 13-6218 (Achari) came on for oral hearing before the undersigned.

Present were Eben Colby on behalf of the Chakkiyattil plaintiffs, Meredith Stewart on behalf of 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 background of this lawsuit in earlier orders, see 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 individuals, including the plaintiffs in the David and Achari cases.
Plaintiffs contend that the subpoenas are not compliant with Louisiana law for two reasons. Citing Louisiana Revised Statute §6:333(C)(2), they first argue that the subpoenas failed to include the required affidavit in which the subpoenaing party 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 date. The return dates on the subpoenas were only eight days after service.
Citing case law, plaintiffs ask the Court to quash 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 that 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 domiciled 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 that the Court must apply Louisiana's conflictof-laws provisions. Under that analysis, Mississippi has the greater interest in the application of its 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 that Louisiana's interest in providing notice to individuals whose banks records have been subpoenaed does not conflict with 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, Louisiana has an interest 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 Louisiana 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 are overbroad. They note that the subpoenas seek production of every single banking record related to hundreds 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. Some employees thus pooled money together to purchase a car. They contend that this hardly constitutes "luxuries."
Plaintiffs maintain that exploring hundreds of individuals' bank records for a period of years is not reasonably calculated to lead to the discovery of 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 the motions 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). Nevertheless, discovery does have “ultimate 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 modify 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 responsible 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 pretermits 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 this ground would be no more than an exercise in formality. 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 are overbroad; M&M does not make this argument. While the subpoenas seek bank records for 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 of the litigation,1 the best course of action here is to order Signal to re-propound the subpoenas and limit them at this time to the named 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 documents 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 numerous protective orders in these lawsuits. Plaintiffs shall do so within fifteen (15) days of receipt of the documents and shall then produce the documents to Signal. III. Conclusion
For the foregoing reasons, IT IS ORDERED that the Motion to Quash Signal's Bank Records Subpoenas [Doc. #1709] in Civil Action No. 08-1220 and the Motion to Quash 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 Appeal or Alternatively to Stay Pending Application for Mandamus Relief filed by Defendants Signal
1

International, L.L.C., Signal International, Inc., and Signal International Texas, G.P. (collectively "Signal").1 Defendants Malvern Burnett, the Law Offices of Malvern Burnett, A.P.C., and Gulf Coast Immigration Law Center, L.L.C. (the "Burnett Defendants") have filed a similar Motion.2 The question presented is whether the Court should certify for interlocutory appeal its orders prohibiting the discovery of certain post-Signal information, including immigration status. For the following reasons, the Court finds that the criteria for interlocutory appeal are not present and that a discretionary stay pending the outcome of a petition for mandamus relief is not warranted. The Motions are DENIED.
BACKGROUND3 A protective order in the above-captioned matters prohibits Signal from discovering, inter alia, the current immigration status of any plaintiff, the current address or place of residence of any plaintiff, and the employers or potential employers of any plaintiff post-termination of employment with Signal.4 Moving Defendants argue the protective order unduly restricts their ability to discover impeachment evidence.5 The Court has rejected this argument on multiple occasions, finding that the in terrorem effect of producing the requested information outweighs Signal's interest in unbridled discovery. Recognizing the futility of beating a dead horse, 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 and R. Doc. 384 in the Achari Cases. The Burnett Defendants 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 476 in the David Case, R. Doc. 285 in the EEOC Case, and R. Doc. 307 in the Achari Cases. 5 The Burnett Defendants also argue the protective order precludes them from 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 non-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 presented, and (3) an immediate appeal would "materially advance the ultimate termination of the litigation."6 The district court cannot certify an order for interlocutory appeal unless all three criteria are present.7 In determining whether certification is appropriate, the Court is mindful that interlocutory appeal is "exceptional" and "does not lie simply to determine the correctness of a judgment."8
LAW AND ANALYSIS The parties spill much ink arguing whether the protective order involves a controlling question of law on which there exists a substantial ground for difference of opinion. The Court need not decide these issues today. For the reasons explained more fully below, certification 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 the need for trial, simplify the issues for trial, or reduce the burden of
6 28 U.S.C. § 1292(b). 7 See Aparicio v. Swan Lake, 643 F.2d 1109, 1110 n.2 (5th Cir. 1981) ("Section 1292(b) sets out three criteria all of which must be met 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 reversal 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 reduce the burden of discovery. 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 decision for at least six months.11 Regardless of the Fifth
Circuit's ruling, the David Case would then have to be returned to the Court's jury
docket, resulting in an additional lengthy delay. Moreover, an extensive delay in the
David Case would likely produce a ripple effect of continuances in the EEOC Case and
the Achari Cases. And once the David Case and the related cases are finally tried,
appealable issues will almost undoubtedly still exist,12 which could 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, at *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) ("An appeal materially advances the termination of litigation when it accelerates or simplifies trial proceedings."). 10 Courts in the Fifth Circuit have recognized that a discovery order is seldom appropriate for interlocutory appeal. See, e.g., In re Tullius, No. EP-11-mc-365-KC., 2011 WL 5006673, at *2 (W.D. Tex. Oct. 20, 2011) ("District courts in the Fifth Circuit are hesitant to grant leave 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 disposition 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 piecemeal appeals are disfavored. See Mohawk Indus., Inc. v. Carpenter, 558 U.S. 100, 106 (2009) ("Permitting piecemeal, prejudgment appeals . . . undermines 'efficient judicial administration' and encroaches upon the prerogatives of district court judges, who play a 'special role' in managing ongoing litigation.) (quoting Firestone Tire & Rubber Co. v. Risjord, 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 relief requested by Moving Defendants—a stay pending resolution of an as-of-yet-filed petition for mandamus relief in the Fifth Circuit. There is no automatic stay of district proceedings while a petition for writ of mandamus is pending.14 Accordingly, any such stay is imposed under the district court's general discretionary authority.15
A district court has inherent authority to manage its docket, which includes the power to stay proceedings.16 The moving party bears a "heavy burden" to demonstrate that a stay is appropriate.17 "Where a discretionary stay is proposed, something close to genuine necessity should be the mother of its invocation."18
For largely the reasons set forth above, Signal has failed to make the necessary showing. The hardship and inconvenience that would result from a stay substantially outweighs any benefit,19 especially in light of the fact that mandamus relief is unlikely to be granted.20 Accordingly, the Court will not issue a stay.
CONCLUSION Signal seeks to appeal an interlocutory ruling, the resolution of which will not materially advance the related cases to final judgment. Accordingly, the Court will not certify the ruling for interlocutory appeal. The 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 Landis, 299 U.S. at 254 (instructing lower courts to "weigh competing interests and maintain 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

 
 Case 2:13-cv-06218-SM-DEK Document 459 Filed 03/23/15 Page 1 of 6

Case 2:13-cv-06218-SM-DEK Document 459 Filed 03/23/15 Page 2 of 6
Krishnakutty v. Signal, et al, Civ. No. 13-6220 Summary of Claims in First Amended Complaint

Claim Made1

Damages Sought2

 Compensatory Damages, including (without

limitation*):

1. THE TRAFFICKING

o Loss of wages

VICTIMS

o Loss of opportunity

PROTECTION ACT OF

o Pain and suffering

2003

o Mental and emotional distress

o Prejudgment interest

18 U.S.C. § 1589 (forced

o Recruitment and visa fees paid to Defendants

labor) and 18 U.S.C. §

o Expenses that Plaintiffs incurred to pay such

1590 (trafficking with

fees, including but not limited to interest from

respect to personage,

loans

slavery, involuntary

o Medical expenses

servitude, or forced

o Damages related to living and working

labor)

conditions

o Mandatory housing and other fees paid to

Am. Compl. ¶¶ 214-230

Signal

 Punitive damages

 Attorneys’ fees

2. RACKETEER

 Compensatory Damages, including (without

INFLUENCED AND

limitation*):

Signal

Claim Brought Against3

Burnett

Global Indo Dewan Resources Ameri-
soft

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

1 Plaintiffs Sabu Puthukkuttumel Veede Krishnakutty and Thampy Putham Prambil Edicula (“Plaintiffs”) assert identical claims in this action.

2 This chart summarizes the allegations in ¶¶ 214-372 of the First Amended Complaint, and is not intended to modify, replace or substitute for those allegations.

* Plaintiffs do not seek damages from any defendants relating to events that occurred after their employment with Signal ended.

3 For purposes of this Summary of Claims, “Signal” means Signal International LLC; “Burnett” means Malvern C. Burnett, and Gulf Coast Immigration Law Center, LLC; “Dewan” means Sachin Dewan and Dewan Consultants Pvt. Ltd.; and “Indo Amerisoft” means Indo AmeriSoft L.L.C. and Kurella Rao.

Case 2:13-cv-06218-SM-DEK Document 459 Filed 03/23/15 Page 3 of 6

CORRUPT

o Loss of wages

ORGANIZATIONS

o Loss of opportunity

ACT

o Pain and suffering

o Mental and emotional distress

18 U.S.C. § 1962(c) and

o Prejudgment interest

18 U.S.C. § 1962(d)

o Recruitment and visa fees paid to Defendants

o Expenses that Plaintiffs incurred to pay such

Am. Compl. ¶¶ 231-279

fees, including but not limited to interest from

loans

o Medical expenses

o Damages related to living and working

conditions

o Mandatory housing and other fees paid to

Signal

 Punitive damages

 Attorneys’ fees

 Compensatory Damages, including (without

limitation*):

3. VIOLATIONS OF THE CIVIL RIGHTS ACT OF 1866

o Loss of wages o Loss of opportunity o Pain and suffering o Mental and emotional distress

42 U.S.C. § 1981 (Discriminatory Treatment)

o Prejudgment interest o Medical expenses

Yes

o Damages related to living and working

conditions

Am. Compl. ¶¶ 280-293

o Mandatory housing and other fees paid to Signal

 Punitive damages

 Attorneys’ fees

4. VIOLATIONS OF THE  Compensatory Damages, including (without

KU KLUX KLAN ACT

limitation*):

OF 1871

o Loss of wages

o Loss of opportunity

Yes

42 U.S.C. § 1985 and the

o Pain and suffering

Thirteenth Amendment

o Mental and emotional distress

o Prejudgment interest

No

No

Yes

Yes

2

No

No

Yes

Yes

Am. Compl. ¶¶ 294-301
5. FRAUD (Mississippi Law)
Am. Compl. ¶¶ 302-316
6. NEGLIGENT MISREPRESENTATION (Mississippi Law)
Am. Compl. ¶¶ 317-331

Case 2:13-cv-06218-SM-DEK Document 459 Filed 03/23/15 Page 4 of 6

o Medical expenses

o Damages related to living and working

conditions

o Mandatory housing and other fees paid to

Signal

 Punitive damages

 Attorneys’ fees

 Compensatory Damages, including (without

limitation*):

o Loss of wages

o Loss of opportunity

o Pain and suffering

o Mental and emotional distress

o Prejudgment interest

o Recruitment and visa fees paid to Defendants

o Expenses that Plaintiffs incurred to pay such fees, including but not limited to interest from

Yes

loans

o Medical expenses

o Damages related to living and working

conditions

o Mandatory housing and other fees paid to

Signal

 Punitive damages

 Attorneys’ fees

 Compensatory Damages, including (without

limitation*):

o Loss of wages

o Loss of opportunity

o Pain and suffering

o Mental and emotional distress o Prejudgment interest

Yes

o Recruitment and visa fees paid to Defendants

o Expenses that Plaintiffs incurred to pay such

fees, including but not limited to interest from

loans

o Medical expenses

Yes

Yes

Yes

Yes

3

Yes

Yes

Yes

Yes

7. BREACH OF CONTRACT (Mississippi Law)
Am. Compl ¶¶ 332-342
8. MONEY HAD AND RECEIVED (Mississippi Law)
Am. Compl. ¶¶ 343-352
9. BREACH OF FIDUCIARY DUTY (Mississippi Law)
Am. Compl. ¶¶ 353-362

Case 2:13-cv-06218-SM-DEK Document 459 Filed 03/23/15 Page 5 of 6

o Damages related to living and working

conditions

o Mandatory housing and other fees paid to

Signal

 Punitive damages

 Attorneys’ fees

 Compensatory Damages, including (without

limitation*):

o Loss of wages

o Loss of opportunity

o Pain and suffering

o Mental and emotional distress,

o Prejudgment interest,

o Recruitment and visa fees paid to Defendants

o Expenses that Plaintiffs incurred to pay such fees, including but not limited to interest from

Yes

loans

o Medical expenses

o Damages related to living and working

conditions

o Mandatory housing and other fees paid to

Signal

 Punitive damages

 Attorneys’ fees

 Compensatory Damages, including (without

limitation*):

o Recruitment and visa fees paid to Defendants

o Mandatory housing and other fees paid to Signal

Yes

o Prejudgment interest

 Punitive damages

 Attorneys’ fees

 Compensatory Damages, including (without

limitation*):

o Loss of wages

No

o Loss of opportunity

o Pain and suffering

4

Yes

Yes

Yes

Yes

Yes

No

Yes

Yes

Yes

Yes

No

No

Case 2:13-cv-06218-SM-DEK Document 459 Filed 03/23/15 Page 6 of 6

o Mental and emotional distress

o Prejudgment interest

o Recruitment and visa fees paid to

Defendants

o Expenses that Plaintiffs incurred to pay such

fees, including but not limited to interest

from loans

 Punitive damages

 Attorneys’ fees

 Constructive Trust

 Compensatory Damages, including (without

limitation*):

o Loss of wages

o Loss of opportunity

o Pain and suffering

o Mental and emotional distress,

o Prejudgment interest,

10. BREACH OF

o Recruitment and visa fees paid to

SPECIAL/CONFIDENT

Defendants

IAL RELATIONSHIP (Mississippi Law)

o Expenses that Plaintiffs incurred to pay such

fees, including but not limited to interest

Yes

from loans

Am. Compl. ¶¶ 363-372

o Medical expenses

o Damages related to living and working

conditions

o Mandatory housing and other fees paid to

Signal

 Punitive damages

 Attorneys’ fees

 Constructive Trust

Yes

Yes

Yes

Yes

DM_US 59615199-2.099747.0243

5

 
 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

 
 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"

1

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

CIVIL ACTION
No. 14-2811 c/w 14-2826,
15-2295, 15-2296 15-2297
SECTION "E"

Applies to: David v. Signal (08-1220); Achari v. Signal (13-6218); Samuel v. Signal (14-2811); Joseph v. Signal (14-2826)
ORDER AND REASONS Before the Court are the Dewan Defendants’ Motions for Summary Judgment on the crossclaims of Co-Defendant Signal International, LLC (“Signal”).1 Signal opposes the Motions.2 The Dewan Defendants have also filed reply memoranda in further support of the Motions for Summary Judgment. The Court has considered these briefs, the record, and the applicable law, and now issues its ruling. For the reasons that follow, the Motions for Summary Judgment are GRANTED IN PART and DENIED IN PART.
FACTUAL AND PROCEDURAL BACKGROUND This matter arises out of an allegedly unlawful recruitment scheme used by Signal to recruit and employ citizens of India in the aftermath of Hurricane Katrina.3 Plaintiffs,

1 This Order and Reasons applies to the identical Motions for Summary Judgment currently pending in David v. Signal (08-1220), R. Docs. 2396, 2397; Achari v. Signal (13-6218), R. Docs. 504, 507; Samuel v. Signal (14-2811), R. Docs. 219, 220; and Joseph v. Signal (14-2826), R. Docs. 216, 217. The motions were originally filed by Defendant Malvern C. Burnett, the Gulf Coast Immigration Law Center, LLC, and the Law Offices of Malvern C. Burnett, APC (“the Burnett Defendants”). Defendants Sachin Dewan and Dewan Consultants, Pvt. Ltd. (“the Dewan Defendants”), thereafter joined in the motions. The Burnett Defendants are no longer defendants to this action. Accordingly, for purposes of this Order and Reasons, the Court treats the Motions for Summary Judgment solely as that of the Dewan Defendants. 2 R. Doc. 513 (in the Achari cases) (13-6218). For simplicity, the Court, where necessary, refers to the Motions for Summary Judgment and related briefs by citing the document numbers assigned those filings in Achari v. Signal (13-6218). The document numbers related to the Motions in the other relevant cases are reflected, supra, in footnote 1. 3 See generally R. Doc. 200 (in the Achari cases) (13-6218).
2

a number of the recruited Indian workers, allege that Signal, among others, recruited
Plaintiffs to work at Signal’s facilities in Pascagoula, Mississippi, post-Hurricane
Katrina.4 Signal allegedly promised Plaintiffs that, in connection with the recruitment
scheme, it would assist Plaintiffs in acquiring permanent residence in the United States.5
Plaintiffs contend, however, that Signal never followed through with these promises or
took steps to assist Plaintiffs in obtaining green cards.6 Moreover, Plaintiffs argue, inter
alia, that they experienced discriminatory treatment at the hands of Signal and were
forced to live in deplorable conditions.7
The present Motions for Summary Judgment concern the crossclaims levied by
Signal against the Burnett Defendants and the Dewan Defendants in (1) David v. Signal
(08-1220); (2) the consolidated cases in Achari v. Signal (13-6218);8 (3) Samuel v. Signal
(14-2811); and (4) Joseph v. Signal (14-2826). Judgment was entered on the crossclaims
in the first David trial9 against Signal and in favor of the Burnett and Dewan
Defendants.10 The Dewan Defendants contend in the present Motions that, because
“identical” crossclaims were alleged and adjudicated in the first David trial,11 Signal’s
4 R. Doc. 200 at 4–5 (in the Achari cases) (13-6218). 5 R. Doc. 200 at 6 (in the Achari cases) (13-6218). 6 R. Doc. 200 at 6–7 (in the Achari cases) (13-6218). 7 R. Doc. 200 at 7 (in the Achari cases) (13-6218). 8 Signal filed crossclaims against the Burnett and Dewan Defendants in each of the cases consolidated in Achari v. Signal. These consolidated cases, along with the document number of Signal’s crossclaims in those cases, include: Thomas v. Signal (14-1818), R. Doc. 370 (E.D. La.); Achari v. Signal (13-6218), R. Doc. 642 (E.D. La.); Chakkiyattil v. Signal (13-6219), R. Doc. 643 (E.D. La.); Krishnakutty v. Signal (136220), R. Doc. 644 (E.D. La.); Devassy v. Signal (13-6221), R. Doc. 645 (E.D. La.); Singh v. Signal (14732), R. Doc. 646 (E.D. La.). 9 The first David trial involved only 5 of the Plaintiffs in David. The claims of the remaining 7 Plaintiffs against the Dewan Defendants, as well as Signal’s related crossclaims against the Dewan Defendants, remain pending in David. 10 R. Doc. 504 at 2 (in the Achari cases) (13-6218); R. Doc. 504-1 at 2–3 (in the Achari cases) (13-6218). 11 Counts 1 through 8 were resolved prior to trial when the Court granted judgment as a matter of law in favor of the Burnett and Dewan Defendants. See David v. Signal (08-1220), R. Doc. 2265. The jury found in favor of the Burnett and Dewan Defendants on the indemnity crossclaims. See David v. Signal (08-1220), R. Doc. 2268-2 at 78–83.
3

crossclaims in David—with respect to the remaining David Plaintiffs—and in the
consolidated Achari cases, as well as the Samuel and Joseph cases, are barred by the
doctrine of res judicata.
LEGAL STANDARDS
A. Summary Judgment Standard
Summary judgment is appropriate only “if the movant shows that there is no
genuine dispute as to any material fact and the movant is entitled to judgment as a matter
of law.”12 “An issue is material if its resolution could affect the outcome of the action.”13
When assessing whether a material factual dispute exists, the Court considers “all of the
evidence in the record but refrains from making credibility determinations or weighing
the evidence.”14 All reasonable inferences are drawn in favor of the non-moving party.15
There is no genuine issue of material fact if, even viewing the evidence in the light most
favorable to the non-moving party, no reasonable trier of fact could find for the non-
moving party, thus entitling the moving party to judgment as a matter of law.16
B. Res Judicata Standard
“Under the doctrine of res judicata, parties and their privies are precluded from
relitigating claims that were or should have been raised in a prior action and have reached
a final judgment on the merits.”17 For the doctrine of res judicata to apply, four
requirements must be satisfied: (1) the parties must be identical in both suits, or the
12 Fed. R. Civ. P. 56. See also Celotex Corp. v. Catrett, 477 U.S. 317, 322–23 (1986). 13 DIRECTV Inc. v. Robson, 420 F.3d 532, 536 (5th Cir. 2005). 14 Delta & Pine Land Co. v. Nationwide Agribusiness Ins. Co., 530 F.3d 395, 398 (5th Cir. 2008). See also Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133, 150–51 (2000). 15 Little v. Liquid Air Corp., 37 F.3d 1069, 1075 (5th Cir. 1994). 16 Smith v. Amedisys, Inc., 298 F.3d 434, 440 (5th Cir. 2002). 17 Metro Charities, Inc. v. Moore, 748 F. Supp. 1156, 1159 (S.D. Miss 1990) (citing Federated Dep’t Stores, Inc. v. Moitie, 452 U.S. 394, 398 (1981)). See also Allen v. McCurry, 449 U.S. 90, 94 (1980) (“The doctrine of res judicata, or claim preclusion, forecloses relitigation of claims that were or could have been raised in a prior action.”).
4

parties must be in privity with parties who were identical in both suits; (2) the prior judgment must have been rendered by a court of competent jurisdiction; (3) the prior judgment must have been a final judgment on the merits; and (4) the same claim or cause of action must be involved in both suits.18
DISCUSSION It is undisputed that the first two requirements of the res judicata analysis are satisfied in this case.19 The Dewan Defendants and Signal agree that (1) the parties in the crossclaims are identical or in privity; and (2) the crossclaims in the first David trial were decided by a court of competent jurisdiction. The principal disputes with respect to the present Motions for Summary Judgment concern the third and fourth requirements of the res judicata analysis. The Court will address each requirement, in turn, below. A. Final Judgment on the Merits The third requirement of the res judicata inquiry, as recited above, requires that the prior judgment be a final judgment on the merits.20 The Dewan Defendants contend it is “self evident” that the prior judgment on Signal’s crossclaims in the first David trial is final and on the merits, noting that a “verdict was issued as a result of a trial o[n] the merits and Judgment was issued pursuant to Rule 54(b).”21 Signal, on the other hand, disputes the assertion that the first David trial resulted in a final judgment on its crossclaims.22 Signal argues that, because it has appealed the Court’s judgment on its crossclaims, the judgment is not final for purposes of res judicata.23 More specifically,
18 See, e.g., Swate v. Hartwell (In re Swate), 99 F.3d 1282, 1286 (5th Cir. 1996); 19 R. Doc. 504-2 at 4–5 (in the Achari cases); R. Doc. 513 at 4 (in the Achari cases) (13-6218). 20 See supra note 18 and accompanying text. 21 R. Doc. 504-2 at 5 (in the Achari cases) (13-6218). 22 R. Doc. 513 at 5 (in the Achari cases) (13-6218). 23 R. Doc. 513 at 5 (in the Achari cases). Signal states that the pendency of its appeal should “defeat” the finality argument. R. Doc. 513 at 5 (in the Achari cases) (13-6218).
5

Signal contends the pendency of an appeal renders the appealed-from judgment
“insufficiently final” for res judicata purposes.
Under Fifth Circuit case law, it is immaterial for res judicata purposes that a prior
judgment has been appealed. The Fifth Circuit has specifically held that “[a] case pending
appeal is res judicata and entitled to full faith and credit unless and until reversed on
appeal.”24 Signal’s argument to the contrary, that its taking of an appeal renders the
Court’s judgment “insufficiently final,” is incorrect.25 Signal’s appeal has, for res judicata
purposes, no bearing on the finality of the Court’s judgment on Signal’s crossclaims in the
first David trial. As a result, the Court finds the third requirement of the res judicata
inquiry satisfied. The judgment on Signal’s crossclaims in the first David trial is, for
purposes of res judicata, final and on the merits. The Court now turns to the fourth
requirement.
B. Same Claims or Causes of Action
The fourth requirement of the res judicata inquiry, as recited above, requires that
the same claims or causes of action be involved in both suits.26 To determine whether two
suits involve the same claims or causes of action, the Fifth Circuit instructs courts to use
the “transactional test” of the Restatement (Second) of Judgments, § 24.27 Under the
24 Comer v. Murphy Oil USA, 718 F.3d 460, 467 (5th Cir. 2013) (quoting Fid. Standard Life Ins. Co. v. First Nat’l Bank & Trust Co., 510 F.2d 272, 273 (5th Cir. 1975) (per curiam)) (internal quotation marks omitted). See also United States v. Munsingwear, Inc., 340 U.S. 36, 39 (1950); 18A CHARLES A. WRIGHT & ARTHUR D. MILLER, FEDERAL PRACTICE AND PROCEDURE § 4427 (2d ed. 2012). 25 Signal cites Griggs v. United States, 253 F. App’x 405 (5th Cir. 2007), for the proposition that a judgment, when appealed, is insufficiently final for res judicata purposes. R. Doc. 513 at 5–6. Signal’s reliance on Griggs for this conclusion is inapposite. Griggs does not hold that a judgment, if appealed, is not final for res judicata purposes. Instead, the Fifth Circuit in Griggs noted, in dicta, that a judgment, which is not appealed, is final, though that judgment may be erroneous or based on law that is no longer controlling. See Griggs, 253 F. App’x at 411. 26 See supra note 18 and accompanying text. 27 See, e.g., In re Southmark Corp., 163 F.3d 925, 934 (5th Cir. 1999) (citing Southmark Prop. v. Charles House Corp., 742 F.2d 862, 870–71 (5th Cir. 1984)); see also Petro-Hunt, L.L.C. v. U.S., 365 F.3d 385, 395– 96 (5th Cir. 2004).
6

transactional test, a prior judgment’s preclusive effect extends “to all or any part of the
transaction, or series of connected transactions, out of which the [original] action
arose.”28 Which grouping of facts constitutes a “transaction” or a “series of transactions”
must “be determined pragmatically, giving weight to such considerations as whether the
facts are related in time, space, origin, or motivation, whether they form a convenient trial
unit, and whether their treatment as a unit conforms to the parties’ expectations or
business understanding or usage.”29 The critical issue under the transactional test is
whether the two actions or suits are based on the “same nucleus of operative facts.”30
In the first David trial, Signal’s crossclaims were enumerated in 10 separate
counts.31 Counts 1 through 8 were Signal’s crossclaims for fraud, breach of fiduciary duty,
malpractice, two counts of breach of contract, unfair trade practices, detrimental reliance,
and tortious interference with a contractual relationship.32 Counts 9 and 10 were Signal’s
crossclaims for indemnity against the Burnett and Dewan Defendants.33 Signal does not
dispute that Counts 1 through 8 arise out of the “same nucleus of operative facts” as its
corresponding, non-indemnity crossclaims in the remaining portion of the David case,
the consolidated Achari cases, and the Samuel and Joseph cases.34 Indeed, Signal
concedes that its non-indemnity crossclaims in these cases satisfy the fourth requirement
of the res judicata inquiry and involve the same claims or causes of action as Signal’s non-
28 Petro-Hunt, 365 F.3d at 395–96 (quoting RESTATEMENT (SECOND) OF JUDGMENTS § 24(1) (1982)) (internal quotation marks omitted). 29 Id. (quoting RESTATEMENT (SECOND) OF JUDGMENTS § 24(2) (1982)) (internal quotation marks omitted). 30 New York Life Ins. Co. v. Gillispie, 203 F.3d 384, 387 (5th Cir. 2000). See also Davis v. Dallas Area Rapid Transit, 383 F.3d 309, 313 (5th Cir. 2004). 31 David v. Signal (08-1220), R. Doc. 1748 at 95–104. 32 David v. Signal (08-1220), R. Doc. 1748 at 95–102. Prior to the trial in David, the Court dismissed Counts 1 through 8 of Signal’s crossclaims, granting the Burnett and Dewan Defendants judgment as a matter of law. David v. Signal (08-1220), R. Doc. 2265. 33 David v. Signal (08-1220), R. Doc. 1748 at 102–104. 34 See R. Doc. 513 at 8–9 (in the Achari cases) (13-6218).
7

indemnity crossclaims adjudicated in the first David trial. Because the parties agree that the first and second requirements of the res judicata analysis are met, and because the Court has found that the third and fourth requirements are met, Signal’s non-indemnity crossclaims are barred by the doctrine of res judicata as a result of the judgment in the first David trial.
The indemnity counts of Signal’s crossclaims—Counts 9 and 10 in the first David trial—require a more lengthy and involved analysis.35 Signal argues, in sum, that its indemnity crossclaims against the Burnett and Dewan Defendants in the first David trial were not based on the same nucleus of operative facts as Signal’s indemnity crossclaims in the remaining portion of the David case, the consolidated Achari cases, and the Samuel and Joseph cases.36 Signal contends its crossclaims for indemnity necessarily involve facts specific to each individual Plaintiff and that the “facts surrounding a given Plaintiff’s recruitment” are dispositive of Signal’s crossclaims for indemnity in each particular case.37 As such, Signal avers that, because facts specific to the remaining Plaintiffs in David, the Plaintiffs in Achari, and the Plaintiffs in Samuel and Joseph were not presented and adjudicated at the first David trial, Signal’s indemnity crossclaims should not be barred by the doctrine of res judicata.38
The Dewan Defendants, on the other hand, argue that, with respect to Signal’s indemnity crossclaims, “the category of damages, the alleged basis of recovery, and the operative facts on which [Signal] bases its claim for recovery are the same as presented in David.”39 The Dewan Defendants maintain the “only difference” is the “amount of
35 See R. Doc. 513 at 9 (in the Achari cases) (13-6218). 36 See R. Doc. 513 at 9–10 (in the Achari cases) (13-6218). 37 R. Doc. 513 at 9–12 (in the Achari cases) (13-6218). 38 R. Doc. 513 at 13–14 (in the Achari cases) (13-6218). 39 R. Doc. 504-2 at 11 (in the Achari cases) (13-6218).
8

damages, if any, for which Signal may be held responsible.”40 The Dewan Defendants do not agree that Signal’s indemnity crossclaims against the Burnett and Dewan Defendants are “plaintiff specific” and turn on the particular facts surrounding the recruitment of each Plaintiff.
The Court agrees with Signal. Signal’s crossclaims for indemnity against the Burnett and Dewan Defendants do require a “plaintiff-specific” analysis. In reaching this conclusion, the Court notes that, in the first David trial, the portion of the Jury Verdict Form which addressed Signal’s crossclaims for indemnity against the Burnett and Dewan Defendants required an analysis of the facts and circumstances unique to the Plaintiffs in that case.41 Specifically, with respect to Signal’s indemnity crossclaims, the Jury Verdict Form referenced the “legal obligation” owed by Signal to the “Plaintiffs in the main action” and whether, “in all fairness,” the Burnett or Dewan Defendants should indemnify Signal for that legal obligation owed by Signal to those specific Plaintiffs.42 Accordingly, in reaching a verdict on Signal’s indemnity crossclaims in the first David trial, the jury was required to consider the specific circumstances and testimony of the Plaintiffs and determine whether the Burnett and Dewan Defendants were required to indemnify Signal for Signal’s conduct with respect to those five David Plaintiffs whose claims were presented in the first trial.
At the first David trial and, specifically, during cross examination, Signal elicited testimony from each Plaintiff as to the conduct of the Burnett and Dewan Defendants and how each Plaintiff’s experience with Burnett and Dewan was unique and distinct. For example, each Plaintiff was asked about unauthorized actions of Burnett and Dewan that
40 R. Doc. 504-2 at 11–12 (in the Achari cases) (13-6218). 41 See David v. Signal (08-1220), R. Doc. 2268-2 at 78–83. 42 See David v. Signal (08-1220), R. Doc. 2268-2 at 78–83 (emphasis added).
9

were relevant to whether the Burnett and Dewan Defendants would be required to indemnify Signal for Signal’s conduct vis-à-vis those David Plaintiffs.
The Court is not persuaded by the argument, set forth by the Dewan Defendants, that Signal’s indemnity crossclaims involve only an assessment of Signal’s and the Burnett and Dewan Defendants’ conduct vis-à-vis each other.43 As stated above, whether the Burnett and Dewan Defendants were required by law to indemnify Signal in the first David trial turned on the particular facts and circumstances surrounding the individual Plaintiffs in that trial. Signal’s indemnity crossclaims in the first David trial are necessarily distinct and do not involve the same claims or causes of action as Signal’s indemnity crossclaims in the remaining portion of David, the consolidated Achari cases, or the Samuel or Joseph cases. Signal’s crossclaims for indemnity against the Burnett and Dewan Defendants are not barred by the doctrine of res judicata.
CONCLUSION For the foregoing reasons, the Court finds that Signal’s crossclaims for indemnity against the Dewan Defendants in the remaining portion of the David case, the consolidated Achari cases, and the Samuel and Joseph cases are not barred by the doctrine of res judicata. Signal’s non-indemnity crossclaims are barred under the doctrine of res judicata. Accordingly; IT IS ORDERED that the Dewan Defendants’ Motions for Summary Judgment44 are hereby GRANTED IN PART and DENIED IN PART. Signal’s non-indemnity crossclaims are barred by the doctrine of res judicata. Signal’s crossclaims for indemnity
43 See R. Doc. 524 at 5–6 (in the Achari cases) (13-6218). 44 R. Doc. 504 (in the Achari cases) (13-6218).
10

against the Burnett and Dewan Defendants are, for the reasons stated above, not barred by the doctrine of res judicata.
New Orleans, Louisiana, this 1st day of December, 2015. _______ _____________ _______ SUSIE MORGAN UNITED STATES DISTRICT JUDGE
11

 
 Case: 2:13-cv-06220-SM-DEK As of: 02/27/2015 02:23 PM CST 1 of 9
U. S. District Court Eastern District of Louisiana (New Orleans) CIVIL DOCKET FOR CASE #: 2:13−cv−06220−SM−DEK

CONSOL

Krishnakutty et al v. Signal International LLC et al Assigned to: Judge Susie Morgan Referred to: Magistrate Judge Daniel E. Knowles, III Lead case: 2:13−cv−06218−SM−DEK Member case: (View Member Case)
Case in other court: Mississippi Southern, 1:13−cv−00319
Cause: 18:1961 Racketeering (RICO) Act
Plaintiff

Date Filed: 10/23/2013 Jury Demand: Plaintiff Nature of Suit: 470 Racketeer/Corrupt Organization Jurisdiction: Federal Question

Sabu Puthukkuttumel Veede Krishnakutty

represented by A. Gregory Grimsal Gordon, Arata, McCollam, Duplantis &Eagan (New Orleans) 201 St. Charles Ave. Suite 4000 New Orleans, LA 70170−4000 (504) 582−1111 Email: ggrimsal@gordonarata.com LEAD ATTORNEY ATTORNEY TO BE NOTICED

John C. Low MCDERMOTT, WILL &EMERY, LLP − Houston 1000 Louisiana Street, Suite 3900 Houston, TX 77002 713/653−1781 Fax: 713/739−7592 Email: jlow@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 305/347−6534 Fax: 305/347−6500 Email: juhlemann@mwe.com TERMINATED: 12/27/2013 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 B. McDuff Robert McDuff, Attorney at Law 767 N. Congress St. Jackson, MS 39202 (601) 969−0802

Case: 2:13-cv-06220-SM-DEK As of: 02/27/2015 02:23 PM CST 2 of 9

Email: RBM@McDuffLaw.com TERMINATED: 12/27/2013 ATTORNEY TO BE NOTICED

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

Steven W. Copley Gordon, Arata, McCollam, Duplantis &Eagan (New Orleans) 201 St. Charles Ave. Suite 4000 New Orleans, LA 70170−4000 (504) 582−1111 Email: scopley@gordonarata.com 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

Plaintiff Thampy Putham Parambil Edicula

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

John C. Low (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 ATTORNEY TO BE NOTICED

Mark H. Churchill (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

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

Scott W. Clark

Case: 2:13-cv-06220-SM-DEK As of: 02/27/2015 02:23 PM CST 3 of 9
(See above for address) TERMINATED: 12/02/2014 PRO HAC VICE
Steven W. Copley (See above for address) ATTORNEY TO BE NOTICED
Steven G. Spears (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

V. Defendant Signal International LLC

represented by Hal D. Ungar Hangartner, Rydberg, Terrell &Hart, LLC One Shell Square 701 Poydras Street Suite 310 New Orleans, LA 70139 504−522−5690 Email: hungar@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 ATTORNEY TO BE NOTICED
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 Suite 310 New Orleans, LA 70139 504−522−5690

Case: 2:13-cv-06220-SM-DEK As of: 02/27/2015 02:23 PM CST 4 of 9

Email: erabbani@hanrylaw.com ATTORNEY TO BE NOTICED

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 ATTORNEY TO BE NOTICED

Patricia Anne F. Bollman Patricia A. Bollman, APLC P. O. Box 13707 New Orleans, LA 70185 504−218−5887 Email: patricia@bollmanfirm.com ATTORNEY TO BE NOTICED

Defendant Indo−Ameri Soft L.L.C.

Defendant Kurella Rao

represented by Kurella Rao #6 Isla Road, Unity Zone Dangriga Belize PRO SE

Defendant Global Resources Inc

Defendant Malvern C. Burnett

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: 10/30/2013 LEAD ATTORNEY

Daniel Edwin Buras , Jr. Buras Law Firm, LLC 301 N. Columbia St. Covington, LA 70433 985−306−1769 Fax: 888−383−4079 Email: DBuras@BurasLawFirm.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-06220-SM-DEK As of: 02/27/2015 02:23 PM CST 5 of 9

ATTORNEY TO BE NOTICED

Defendant
Law Offices of Malvern C. Burnett, A.P.C.

represented by Arthur D. Carlisle (See above for address) TERMINATED: 10/30/2013 LEAD ATTORNEY

Daniel Edwin Buras , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Timothy W. Cerniglia (See above for address) ATTORNEY TO BE NOTICED

Defendant
Gulf Coast Immigration Law Center, L.L.C.

represented by Arthur D. Carlisle (See above for address) TERMINATED: 10/30/2013 LEAD ATTORNEY

Daniel Edwin Buras , Jr. (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Timothy W. Cerniglia (See above for address) ATTORNEY TO BE NOTICED

Defendant Sachin Dewan

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. also known as Medtech Consultants

represented by Stephen H. Shapiro (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Date Filed 08/07/2013
08/07/2013

# Docket Text
1 COMPLAINT against Malvern C. Burnett, Sachin Dewan, Dewan Consultants Pvt. Ltd., Global Resources, Inc., Gulf Coast Immigration Law Center, LLC, Indo−Ameri Soft LLC, Law Offices of Malvern C. Burnett, A.P.C., Kurella Rao, Signal International LLC (Filing fee $ 400; receipt number 14643004822), filed by Thampy Putham Parambil Edicula, Sabu Puthukkuttumel Veede Krishnakutty. Jury trial requested. (Attachments: # 1 Civil Cover Sheet)(JCH) [Transferred from mssd on 10/23/2013.] (Entered: 08/07/2013)
2 RICO Statement by Thampy Putham Parambil Edicula, Sabu Puthukkuttumel Veede Krishnakutty. (Attachments: # 1 Exhibit 1 − RICO Fraud Chart)(JCH) [Transferred from mssd on 10/23/2013.] (Entered: 08/07/2013)

Case: 2:13-cv-06220-SM-DEK As of: 02/27/2015 02:23 PM CST 6 of 9

08/07/2013 08/30/2013 09/03/2013 09/06/2013
09/06/2013 09/06/2013
09/13/2013 09/13/2013 09/13/2013 09/13/2013 09/13/2013

3 Summons Issued as to Malvern C. Burnett, Sachin Dewan, Dewan Consultants Pvt. Ltd., Global Resources, Inc., Gulf Coast Immigration Law Center, LLC, Indo−Ameri Soft LLC, Law Offices of Malvern C. Burnett, A.P.C., Kurella Rao, Signal International LLC. (JCH) [Transferred from mssd on 10/23/2013.] (Entered: 08/07/2013)
4 Ex Parte MOTION for Extension of Time to File Answer re 1 Complaint, by Signal International LLC (Ungar, Hal) [Transferred from mssd on 10/23/2013.] (Entered: 08/30/2013)
TEXT ORDER ONLY The Court finds that the Defendant, Signal International L.L.C.'s 4 Motion for Extension of Time to Answer should be granted. Signal International LLC must answer or otherwise lead on or prior to 9/20/2013.No further written order shall be issued by this Court Signed by Magistrate Judge John M. Roper on September 3,2013 (Nicaud, Jenny) [Transferred from mssd on 10/23/2013.] (Entered: 09/03/2013)
5 ***DISREGARD ENTRY − Same has been reentered as document 6 with exhibits*** Rule 16(a) Initial Order: Telephonic Case Management Conference set for 10/24/2013 at 09:15 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. (VLK) Modified on 9/6/2013 (VLK). [Transferred from mssd on 10/23/2013.] (Entered: 09/06/2013)
DOCKET ANNOTATION as to # 5. Disregard entry as the exhibits were not attached. The Rule 16(a) Initial Order will be reentered with the exhibits attached. (VLK) [Transferred from mssd on 10/23/2013.] (Entered: 09/06/2013)
6 Rule 16(a) Initial Order: Telephonic Case Management Conference set for 10/24/2013 at 09:15 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: 09/06/2013)
7 MOTION for John C. Low to Appear Pro Hac Vice by Thampy Putham Parambil Edicula, Sabu Puthukkuttumel Veede Krishnakutty (Attachments: # 1 Exhibit Ex−1 Certificiate of Good Standing− State, # 2 Exhibit Ex−2 Certificate of Good Standing− U.S. District Court)(McDuff, Robert) [Transferred from mssd on 10/23/2013.] (Entered: 09/13/2013)
Pro Hac Vice fee paid for John C. Low receipt number 0538−2511748 $ 100 (McDuff, Robert) [Transferred from mssd on 10/23/2013.] (Entered: 09/13/2013)
8 MOTION for Scott W. Clark to Appear Pro Hac Vice by Thampy Putham Parambil Edicula, Sabu Puthukkuttumel Veede Krishnakutty (Attachments: # 1 Exhibit Ex−1 Certificate of Good Standing−State, # 2 Exhibit Ex−2 Certificate of Good Standing− U.S. District Court)(McDuff, Robert) [Transferred from mssd on 10/23/2013.] (Entered: 09/13/2013)
Pro Hac Vice fee paid for Scott W. Clark receipt number 0538−2511763 $ 100 (McDuff, Robert) [Transferred from mssd on 10/23/2013.] (Entered: 09/13/2013)
9 MOTION for Steven G. Spears to Appear Pro Hac Vice by Thampy Putham Parambil Edicula, Sabu Puthukkuttumel Veede Krishnakutty (Attachments: # 1 Exhibit Ex−1 Certificate of Good Standing−State, # 2 Exhibit Ex−2 Certificate of Good Standing− U.S. District Court)(McDuff, Robert) [Transferred from mssd on 10/23/2013.] (Entered: 09/13/2013)

Case: 2:13-cv-06220-SM-DEK As of: 02/27/2015 02:23 PM CST 7 of 9

09/13/2013 09/16/2013 09/20/2013 09/20/2013
09/25/2013
09/25/2013 09/26/2013
09/27/2013 09/30/2013
10/02/2013 10/02/2013 10/02/2013 10/03/2013

Pro Hac Vice fee paid for Steven G. Spears receipt number 0538−2511777 $ 100 (McDuff, Robert) [Transferred from mssd on 10/23/2013.] (Entered: 09/13/2013)
10 ORDER granting 7 Motion to Appear Pro Hac Vice; granting 8 Motion to Appear Pro Hac Vice; granting 9 Motion to Appear Pro Hac Vice Signed by Magistrate Judge John M. Roper on September 16,2013 (JFN) [Transferred from mssd on 10/23/2013.] (Entered: 09/16/2013)
11 MOTION to Change Venue /Transfer, Pursuant to First−Filed Rule, MOTION to Dismiss Partially For Failure to State a Claim Upon Which Relief Can Be Granted by Signal International LLC (Ungar, Hal) [Transferred from mssd on 10/23/2013.] (Entered: 09/20/2013)
12 MEMORANDUM in Support re 11 MOTION to Change Venue /Transfer, Pursuant to First−Filed Rule MOTION to Dismiss Partially For Failure to State a Claim Upon Which Relief Can Be Granted filed by Signal International LLC (Attachments: # 1 Exhibit 1 − SPLC Press Release, # 2 Exhibit 2 − Consent to Sue (Sabu Krishnakutty))(Ungar, Hal) [Transferred from mssd on 10/23/2013.] (Entered: 09/20/2013)
13 MOTION for Justin Uhlemann to Appear Pro Hac Vice by Thampy Putham Parambil Edicula, Sabu Puthukkuttumel Veede Krishnakutty (Attachments: # 1 Exhibit Ex−1 Certificate of Good Standing−State, # 2 Exhibit Certificate of Good Standing−District Court)(McDuff, Robert) [Transferred from mssd on 10/23/2013.] (Entered: 09/25/2013)
Pro Hac Vice fee paid for Justin Uhlemann receipt number 0538−2520217 $ 100 (McDuff, Robert) [Transferred from mssd on 10/23/2013.] (Entered: 09/25/2013)
TEXT ORDER ONLY The Court finds that the motion of Justin Uhlemann to 13 to appear pro hac vice on behalf of Plaintiffs 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 September 26,2013 (Nicaud, Jenny) [Transferred from mssd on 10/23/2013.] (Entered: 09/26/2013)
14 MOTION for Timothy W. Cerniglia to Appear Pro Hac Vice by Malvern C. Burnett (Carlisle, Arthur) [Transferred from mssd on 10/23/2013.] (Entered: 09/27/2013)
TEXT ORDER ONLY The Court finds that 14 motion of Thomas Cerniglia to Appear Pro Hac Vice on behalf of Defendant, Malvern Burnett 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 September 30,2013 (JFN) Modified on 10/8/2013 (JFN). [Transferred from mssd on 10/23/2013.] (Entered: 09/30/2013)
15 (DISGREGARD) MOTION to Dismiss by Malvern C. Burnett (Carlisle, Arthur) Modified on 10/3/2013 (wld). [Transferred from mssd on 10/23/2013.] (Entered: 10/02/2013)
16 MOTION to Dismiss by Malvern C. Burnett (Carlisle, Arthur) [Transferred from mssd on 10/23/2013.] (Entered: 10/02/2013)
17 MEMORANDUM in Support re 16 MOTION to Dismiss filed by Malvern C. Burnett (Carlisle, Arthur) [Transferred from mssd on 10/23/2013.] (Entered: 10/02/2013)
DOCKET ANNOTATION as to #15. This motion was refiled as document #16. Motion #15 will be terminated. Also, the main document to #16 and #17 are not dated, only the certificates of service are dated. Pursuant to 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. Documents are undated, but the date will be construed as the date of electronic filing. Attorney is advised to follow this rule in future filings by also dating the main document. Attorney is not required to refile. (wld) [Transferred from mssd on 10/23/2013.] (Entered: 10/03/2013)

Case: 2:13-cv-06220-SM-DEK As of: 02/27/2015 02:23 PM CST 8 of 9

10/03/2013 10/03/2013
10/04/2013 10/08/2013
10/09/2013 10/09/2013 10/15/2013 10/15/2013
10/15/2013 10/15/2013 10/16/2013

18 Emergency MOTION to Stay Proceedings by Signal International LLC (Ungar, Hal) [Transferred from mssd on 10/23/2013.] (Entered: 10/03/2013)
19 MEMORANDUM in Support re 18 Emergency MOTION to Stay Proceedings filed by 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)
20 Unopposed MOTION for Extension of Time to File Response/Reply as to 11 MOTION to Change Venue /Transfer, Pursuant to First−Filed Rule MOTION to Dismiss Partially For Failure to State a Claim Upon Which Relief Can Be Granted by Thampy Putham Parambil Edicula, Sabu Puthukkuttumel Veede Krishnakutty (McDuff, Robert) [Transferred from mssd on 10/23/2013.] (Entered: 10/04/2013)
TEXT ONLY ORDER granting 20 Motion for Extension of Time to File Response/Reply re 11 MOTION to Change Venue /Transfer, Pursuant to First−Filed Rule MOTION to Dismiss Partially For Failure to State a Claim Upon Which Relief Can Be Granted. Responses due by 10/15/2013. NO FURTHER WRITTEN ORDER WILL ISSUE FROM THE COURT. Signed by Chief District Judge Louis Guirola, Jr on 10/8/13. (Whitsitt, K) [Transferred from mssd on 10/23/2013.] (Entered: 10/08/2013)
21 MOTION to Appoint Counsel / Enroll as Counsel, Alan D. Weinberger, by Signal International LLC (Ungar, Hal) [Transferred from mssd on 10/23/2013.] (Entered: 10/09/2013)
DOCKET ANNOTATION as to #21: 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, but the date will be construed as the date of electronic filing. Attorney is advised to follow this rule in future filings. (PKS) [Transferred from mssd on 10/23/2013.] (Entered: 10/09/2013)
22 RESPONSE in Opposition re 11 MOTION to Change Venue /Transfer, Pursuant to First−Filed Rule MOTION to Dismiss Partially For Failure to State a Claim Upon Which Relief Can Be Granted filed by Thampy Putham Parambil Edicula, Sabu Puthukkuttumel Veede Krishnakutty (Uhlemann − PHV, Justin) [Transferred from mssd on 10/23/2013.] (Entered: 10/15/2013)
23 MEMORANDUM in Opposition re 11 MOTION to Change Venue /Transfer, Pursuant to First−Filed Rule MOTION to Dismiss Partially For Failure to State a Claim Upon Which Relief Can Be Granted filed by Thampy Putham Parambil Edicula, Sabu Puthukkuttumel Veede Krishnakutty (Attachments: # 1 Exhibit A − David Decertification Order, # 2 Exhibit B − EEOC Order, # 3 Exhibit C − Indian Contract Law, # 4 Exhibit D − Link Cited By Signal)(Uhlemann − PHV, Justin) [Transferred from mssd on 10/23/2013.] (Entered: 10/15/2013)
24 RESPONSE in Opposition re 18 Emergency MOTION to Stay Proceedings filed by Thampy Putham Parambil Edicula, Sabu Puthukkuttumel Veede Krishnakutty (Uhlemann − PHV, Justin) [Transferred from mssd on 10/23/2013.] (Entered: 10/15/2013)
25 MEMORANDUM in Opposition re 18 Emergency MOTION to Stay Proceedings filed by Thampy Putham Parambil Edicula, Sabu Puthukkuttumel Veede Krishnakutty (Attachments: # 1 Exhibit 1 − Achari Motion for Limited Consolidation)(Uhlemann − PHV, Justin) [Transferred from mssd on 10/23/2013.] (Entered: 10/15/2013)
TEXT ONLY ORDER STAYING PROCEEDINGS: This matter is before the Court on Motion to Stay Proceedings 18 filed by Signal International, LLC, 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

Case: 2:13-cv-06220-SM-DEK As of: 02/27/2015 02:23 PM CST 9 of 9

10/16/2013 10/18/2013 10/18/2013 10/18/2013
10/23/2013 10/24/2013

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 Order set for October 24, 2013 is hereby CANCELLED. (VLK) [Transferred from mssd on 10/23/2013.] (Entered: 10/16/2013)
TEXT ORDER ONLY Counsel has represented to the Court that he is withdrawing 21 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)
Pro Hac Vice fee paid by Timothy W. Cerniglia $ 100, receipt number 14643005041. (JCH) [Transferred from mssd on 10/23/2013.] (Entered: 10/18/2013)
26 ORDER granting Motion to Change Venue. Consolidated cases are transferred to the US District Court for the Eastern District of Louisiana; and granting 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)
27 Case transferred in from District of Mississippi Southern; Case Number 1:13−cv−00319. Electronic file certified copy of transfer order and docket sheet received (jtd) (Entered: 10/23/2013)
28 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.(blg) (Entered: 10/25/2013)

 
 Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 1 of 247
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 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 Gordon, Arata, McCollam, Duplantis &Eagan (New Orleans) 201 St. Charles Ave. Suite 4000 New Orleans, LA 70170−4000 504−569−1650 Email: mgrabill@gordonarata.com LEAD ATTORNEY ATTORNEY TO BE NOTICED

A. Gregory Grimsal Gordon, Arata, McCollam, Duplantis &Eagan (New Orleans) 201 St. Charles Ave. Suite 4000 New Orleans, LA 70170−4000 (504) 582−1111 Email: ggrimsal@gordonarata.com 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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 2 of 247
LATHAM &WATKINS, LLP − New York 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 PRO HAC VICE ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 3 of 247
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 PRO HAC VICE ATTORNEY TO BE NOTICED
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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 4 of 247
ATTORNEY TO BE NOTICED
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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 5 of 247

ATTORNEY TO BE NOTICED

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, McCollam, Duplantis &Eagan (New Orleans) 201 St. Charles Ave. Suite 4000 New Orleans, LA 70170−4000 (504) 582−1111 Email: scopley@gordonarata.com 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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 6 of 247
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) 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) PRO HAC VICE ATTORNEY TO BE NOTICED
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: 04/03/2016 11:37 AM CDT 7 of 247

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 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)

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 8 of 247
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) 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) PRO HAC VICE ATTORNEY TO BE NOTICED
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)

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 9 of 247

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 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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 10 of 247
(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) 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) PRO HAC VICE ATTORNEY TO BE NOTICED
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: 04/03/2016 11:37 AM CDT 11 of 247

(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: 04/03/2016 11:37 AM CDT 12 of 247
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) 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) PRO HAC VICE ATTORNEY TO BE NOTICED
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: 04/03/2016 11:37 AM CDT 13 of 247

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 ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 14 of 247
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) 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) PRO HAC VICE ATTORNEY TO BE NOTICED
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: 04/03/2016 11:37 AM CDT 15 of 247

Plaintiff Mouleswararao Guntamukkala

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) 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: 04/03/2016 11:37 AM CDT 16 of 247
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) 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) PRO HAC VICE ATTORNEY TO BE NOTICED
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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 17 of 247

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

Christopher R. Harris (See above for address)

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 18 of 247
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) 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) PRO HAC VICE ATTORNEY TO BE NOTICED
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: 04/03/2016 11:37 AM CDT 19 of 247

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) TERMINATED: 04/02/2014 PRO HAC VICE

Christopher R. Harris

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 20 of 247
(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) 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) PRO HAC VICE ATTORNEY TO BE NOTICED
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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 21 of 247

(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

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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 22 of 247
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) 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) PRO HAC VICE ATTORNEY TO BE NOTICED
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: 04/03/2016 11:37 AM CDT 23 of 247

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 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: 04/03/2016 11:37 AM CDT 24 of 247
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) 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) PRO HAC VICE ATTORNEY TO BE NOTICED
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: 04/03/2016 11:37 AM CDT 25 of 247

Plaintiff Parshottam Ramchandra Mangani

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) 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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 26 of 247
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) 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) PRO HAC VICE ATTORNEY TO BE NOTICED
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: 04/03/2016 11:37 AM CDT 27 of 247

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

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: 04/03/2016 11:37 AM CDT 28 of 247
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) 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) PRO HAC VICE ATTORNEY TO BE NOTICED
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)

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 29 of 247

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 (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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 30 of 247
(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) 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) PRO HAC VICE ATTORNEY TO BE NOTICED
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: 04/03/2016 11:37 AM CDT 31 of 247

(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

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: 04/03/2016 11:37 AM CDT 32 of 247
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) 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) PRO HAC VICE ATTORNEY TO BE NOTICED
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: 04/03/2016 11:37 AM CDT 33 of 247

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 Johny 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

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: 04/03/2016 11:37 AM CDT 34 of 247
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) 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) PRO HAC VICE ATTORNEY TO BE NOTICED
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: 04/03/2016 11:37 AM CDT 35 of 247

Plaintiff Nandhakumar Nagaraj

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) 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: 04/03/2016 11:37 AM CDT 36 of 247
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) 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) PRO HAC VICE ATTORNEY TO BE NOTICED
Kirk A. Wilkinson (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Matthew S. Salerno (See above for address) PRO HAC VICE

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 37 of 247

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 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)

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 38 of 247
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) 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) PRO HAC VICE ATTORNEY TO BE NOTICED
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: 04/03/2016 11:37 AM CDT 39 of 247

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) 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: 04/03/2016 11:37 AM CDT 40 of 247
(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) 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) PRO HAC VICE ATTORNEY TO BE NOTICED
Kirk A. Wilkinson (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Matthew S. Salerno

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 41 of 247

(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 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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 42 of 247
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) 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) PRO HAC VICE ATTORNEY TO BE NOTICED
Kirk A. Wilkinson (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 43 of 247

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 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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 44 of 247
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) 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) PRO HAC VICE ATTORNEY TO BE NOTICED
Kirk A. Wilkinson (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 45 of 247

Plaintiff Justin Poulose

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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 46 of 247
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) 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) PRO HAC VICE ATTORNEY TO BE NOTICED
Matthew S. Salerno (See above for address) PRO HAC VICE

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 47 of 247

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 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)

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 48 of 247
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) 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) PRO HAC VICE ATTORNEY TO BE NOTICED
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: 04/03/2016 11:37 AM CDT 49 of 247

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 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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 50 of 247
(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) 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) PRO HAC VICE ATTORNEY TO BE NOTICED
Kirk A. Wilkinson (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Matthew S. Salerno

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 51 of 247

(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 Mookaparambil Itty Raveendranathan

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: 04/03/2016 11:37 AM CDT 52 of 247
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
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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 53 of 247

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

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: 04/03/2016 11:37 AM CDT 54 of 247
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) 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) PRO HAC VICE ATTORNEY TO BE NOTICED
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: 04/03/2016 11:37 AM CDT 55 of 247

Plaintiff Ranjit Singh

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) 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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 56 of 247
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) 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) PRO HAC VICE ATTORNEY TO BE NOTICED
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: 04/03/2016 11:37 AM CDT 57 of 247

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

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: 04/03/2016 11:37 AM CDT 58 of 247
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) 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) PRO HAC VICE ATTORNEY TO BE NOTICED
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)

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 59 of 247

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 Ninan John Tharakan

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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 60 of 247
(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) 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) PRO HAC VICE ATTORNEY TO BE NOTICED
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: 04/03/2016 11:37 AM CDT 61 of 247

(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

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: 04/03/2016 11:37 AM CDT 62 of 247
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) 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) PRO HAC VICE ATTORNEY TO BE NOTICED
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: 04/03/2016 11:37 AM CDT 63 of 247

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 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: 04/03/2016 11:37 AM CDT 64 of 247
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) 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) PRO HAC VICE ATTORNEY TO BE NOTICED
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: 04/03/2016 11:37 AM CDT 65 of 247

Plaintiff Shahi Vijayan

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) 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: 04/03/2016 11:37 AM CDT 66 of 247
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) 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) PRO HAC VICE ATTORNEY TO BE NOTICED
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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 67 of 247

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 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)

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 68 of 247
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) 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) PRO HAC VICE ATTORNEY TO BE NOTICED
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: 04/03/2016 11:37 AM CDT 69 of 247

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
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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 70 of 247
(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) 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) PRO HAC VICE ATTORNEY TO BE NOTICED
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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 71 of 247

(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 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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 72 of 247
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) 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) PRO HAC VICE ATTORNEY TO BE NOTICED
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: 04/03/2016 11:37 AM CDT 73 of 247

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 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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 74 of 247
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) 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) PRO HAC VICE ATTORNEY TO BE NOTICED
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: 04/03/2016 11:37 AM CDT 75 of 247

Plaintiff Thansilas Joseph

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) 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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 76 of 247
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) 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) PRO HAC VICE ATTORNEY TO BE NOTICED
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: 04/03/2016 11:37 AM CDT 77 of 247

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 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)

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 78 of 247
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) 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) PRO HAC VICE ATTORNEY TO BE NOTICED
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)

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 79 of 247

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 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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 80 of 247
(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) 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) PRO HAC VICE ATTORNEY TO BE NOTICED
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: 04/03/2016 11:37 AM CDT 81 of 247

(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 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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 82 of 247
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) 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) PRO HAC VICE ATTORNEY TO BE NOTICED
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: 04/03/2016 11:37 AM CDT 83 of 247

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 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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 84 of 247
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) 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) PRO HAC VICE ATTORNEY TO BE NOTICED
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: 04/03/2016 11:37 AM CDT 85 of 247

Plaintiff
Praveen Kulathum Muriyi Gopalakrishnan

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) 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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 86 of 247
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) 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) PRO HAC VICE ATTORNEY TO BE NOTICED
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: 04/03/2016 11:37 AM CDT 87 of 247

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 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)

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 88 of 247
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) 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) PRO HAC VICE ATTORNEY TO BE NOTICED
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)

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 89 of 247

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 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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 90 of 247
(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) 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) PRO HAC VICE ATTORNEY TO BE NOTICED
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: 04/03/2016 11:37 AM CDT 91 of 247

(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 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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 92 of 247
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) 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) PRO HAC VICE ATTORNEY TO BE NOTICED
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: 04/03/2016 11:37 AM CDT 93 of 247

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 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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 94 of 247
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) 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) PRO HAC VICE ATTORNEY TO BE NOTICED
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: 04/03/2016 11:37 AM CDT 95 of 247

Plaintiff Bhaskaran Sreedharan Kutty

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) 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: 04/03/2016 11:37 AM CDT 96 of 247
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) 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) PRO HAC VICE ATTORNEY TO BE NOTICED
Kirk A. Wilkinson (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Matthew S. Salerno (See above for address) PRO HAC VICE

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 97 of 247
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

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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 98 of 247
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 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 −

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 99 of 247

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. 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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 100 of 247

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
Ampattu Varughese Mathew (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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 101 of 247

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
Anthony Sajan Oottuparambil Michael (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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 102 of 247

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
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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 103 of 247

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 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: 04/03/2016 11:37 AM CDT 104 of 247

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

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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 105 of 247

(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
Mandeep Singh (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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 106 of 247

(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
John Malakaran Thomas (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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 107 of 247

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

Consol Plaintiff
Saju Christy Vallarian (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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 108 of 247

Isaac Wilson Vazhikudilil (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
Benny Yohannan (13−6221)

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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 109 of 247

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
Prasad Kunju Kunju (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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 110 of 247

(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
Sabu Puthukkuttumel Veede Krishnakutty (13−6220)

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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 111 of 247
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 PRO HAC VICE ATTORNEY TO BE NOTICED
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 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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 112 of 247

Consol Plaintiff
Thampy Putham Parambil Edicula (13−6220)

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
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 (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
John C. Low− PHV (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 113 of 247

(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 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)

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 114 of 247

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

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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 115 of 247

Consol Plaintiff Radhakrishnan Kakkathiruthi (13−6219)
Consol Plaintiff John Abraham Kalampukatt (13−6219)

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
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
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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 116 of 247

Consol Plaintiff Thomas Baby Madakkameprathu (13−6219)
Consol Plaintiff Anthony Marian (13−6219)
Consol Plaintiff Jacob Mathew (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
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
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: 04/03/2016 11:37 AM CDT 117 of 247

(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
Davis Mathai Meledan (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
Francis Kottackal Ouseph (13−6219)

represented by Eben P. Colby (See above for address) LEAD ATTORNEY PRO HAC VICE

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 118 of 247

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

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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 119 of 247

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 Pillai (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
Pradeep Chembil Raman (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: 04/03/2016 11:37 AM CDT 120 of 247

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 (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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 121 of 247

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 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)

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 122 of 247

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 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)

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 123 of 247

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

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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 124 of 247

Consol Plaintiff Jaison Antony Thekkumpuram (13−6219)
Consol Plaintiff Pravin Kumar Singh (14−732)

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
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
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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 125 of 247

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 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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 126 of 247

(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 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 Kaye, Scholer, LLP (New York) 425 Park Ave. New York, NY 10022−3509 212−836−8510 Email: jane.parver@kayescholer.com PRO HAC VICE ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 127 of 247

Michael Blechman Kaye, Scholer, LLP (New York) 425 Park Ave. New York, NY 10022−3509 212−836−8353 Email: michael.blechman@kayescholer.com PRO HAC VICE ATTORNEY TO BE NOTICED

Michael S. Bullerman Kaye, Scholer, LLP (New York) 425 Park Ave. New York, NY 10022−3509 212−836−8000 Email: michael.bullerman@kayescholer.com PRO HAC VICE 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

Thomas J. Szivos Kaye, Scholer, LLP (New York) 425 Park Ave. New York, NY 10022−3509 212−836−8726 Email: thomas.szivos@kayescholer.com PRO HAC VICE 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 Kaye, Scholer, LLP (New York) 425 Park Ave. New York, NY 10022−3509 212−836−8325 Email: yonina.rosenbaum@kayescholer.com PRO HAC VICE 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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 128 of 247

Consol Plaintiff
Saji Chettiyara Baby (14−1818)

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) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael Blechman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael S. Bullerman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Thomas J. Szivos (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE
Yonina Rosenbaum (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
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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 129 of 247

Consol Plaintiff
Sarma Venkata Satyanarayana Bhiri (14−1818)

Jane W. Parver (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael Blechman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael S. Bullerman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Thomas J. Szivos (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE
Yonina Rosenbaum (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
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) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael Blechman (See above for address) PRO HAC VICE

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 130 of 247

ATTORNEY TO BE NOTICED

Michael S. Bullerman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Thomas J. Szivos (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE

Yonina Rosenbaum (See above for address) PRO HAC VICE 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

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) PRO HAC VICE ATTORNEY TO BE NOTICED

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

Michael S. Bullerman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Randolph S. Sherman (See above for address)

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 131 of 247

PRO HAC VICE ATTORNEY TO BE NOTICED

Thomas J. Szivos (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE

Yonina Rosenbaum (See above for address) PRO HAC VICE 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

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

Jane W. Parver (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

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

Michael S. Bullerman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Thomas J. Szivos (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Tricia Beckles

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 132 of 247

(See above for address) TERMINATED: 09/08/2015 PRO HAC VICE

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

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

Michael S. Bullerman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Thomas J. Szivos (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE

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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 133 of 247

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) PRO HAC VICE ATTORNEY TO BE NOTICED

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

Michael S. Bullerman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Thomas J. Szivos (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE

Yonina Rosenbaum (See above for address) PRO HAC VICE 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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 134 of 247

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) PRO HAC VICE ATTORNEY TO BE NOTICED

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

Michael S. Bullerman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Thomas J. Szivos (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE

Yonina Rosenbaum (See above for address) PRO HAC VICE 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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 135 of 247

ATTORNEY TO BE NOTICED

Jane W. Parver (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

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

Michael S. Bullerman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Thomas J. Szivos (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE

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

Michael Blechman (See above for address)

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 136 of 247

PRO HAC VICE ATTORNEY TO BE NOTICED

Michael S. Bullerman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Thomas J. Szivos (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE

Yonina Rosenbaum (See above for address) PRO HAC VICE 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

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) PRO HAC VICE ATTORNEY TO BE NOTICED

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

Michael S. Bullerman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Randolph S. Sherman

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 137 of 247

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

Thomas J. Szivos (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE

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

Consol Plaintiff
Srinu Kalla (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) PRO HAC VICE ATTORNEY TO BE NOTICED

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

Michael S. Bullerman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Thomas J. Szivos (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 138 of 247

Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE

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

Consol Plaintiff
Joseph Thomas Kanjiraparambil (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) PRO HAC VICE ATTORNEY TO BE NOTICED

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

Michael S. Bullerman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Thomas J. Szivos (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE

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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 139 of 247

Consol Plaintiff Subranarayanan Karuppiah (14−1818)
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) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael Blechman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael S. Bullerman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Thomas J. Szivos (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE
Yonina Rosenbaum (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
Meredith B. Stewart (See above for address)

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 140 of 247

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) PRO HAC VICE ATTORNEY TO BE NOTICED

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

Michael S. Bullerman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Thomas J. Szivos (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE

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

Consol Plaintiff
Sivakumar Ramakrishnan Nair (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)

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 141 of 247

PRO HAC VICE ATTORNEY TO BE NOTICED

Jane W. Parver (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

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

Michael S. Bullerman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Thomas J. Szivos (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE

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

Michael Blechman

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 142 of 247

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

Michael S. Bullerman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Thomas J. Szivos (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE

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

Consol Plaintiff
Bhaskararao Nimmadala (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) PRO HAC VICE ATTORNEY TO BE NOTICED

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

Michael S. Bullerman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 143 of 247

Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Thomas J. Szivos (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE

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

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

Jane W. Parver (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

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

Michael S. Bullerman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Thomas J. Szivos (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 144 of 247

Consol Plaintiff
Baiju Paul (14−1818)

Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE
Yonina Rosenbaum (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
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) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael Blechman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael S. Bullerman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Thomas J. Szivos (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE
Yonina Rosenbaum (See above for address) PRO HAC VICE

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 145 of 247

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) PRO HAC VICE ATTORNEY TO BE NOTICED

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

Michael S. Bullerman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Thomas J. Szivos (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE

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

Consol Plaintiff
Kantibhai Khemabhai Prajapati (14−1818)

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

Meredith B. Stewart

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 146 of 247

(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) PRO HAC VICE ATTORNEY TO BE NOTICED

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

Michael S. Bullerman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Thomas J. Szivos (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE

Yonina Rosenbaum (See above for address) PRO HAC VICE 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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 147 of 247

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

Jane W. Parver (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

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

Michael S. Bullerman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Thomas J. Szivos (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE

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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 148 of 247

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

Michael S. Bullerman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Thomas J. Szivos (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE

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

Consol Plaintiff
George Kutty Puthiya P Thomas (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) PRO HAC VICE ATTORNEY TO BE NOTICED

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

Michael S. Bullerman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 149 of 247

Consol Plaintiff
David Raju Tuloori (14−1818)

Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Thomas J. Szivos (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE
Yonina Rosenbaum (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
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) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael Blechman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael S. Bullerman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Thomas J. Szivos (See above for address) PRO HAC VICE

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 150 of 247

ATTORNEY TO BE NOTICED

Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE

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

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

Michael S. Bullerman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Thomas J. Szivos (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE

Yonina Rosenbaum (See above for address)

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 151 of 247

PRO HAC VICE 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) PRO HAC VICE ATTORNEY TO BE NOTICED

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

Michael S. Bullerman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Thomas J. Szivos (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED

Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE

Yonina Rosenbaum (See above for address) PRO HAC VICE 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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 152 of 247
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) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael Blechman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Michael S. Bullerman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Randolph S. Sherman (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Thomas J. Szivos (See above for address) PRO HAC VICE ATTORNEY TO BE NOTICED
Tricia Beckles (See above for address) TERMINATED: 09/08/2015 PRO HAC VICE
Yonina Rosenbaum (See above for address) PRO HAC VICE 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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 153 of 247
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 ATTORNEY TO BE NOTICED
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 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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 154 of 247

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 Patricia A. Bollman, APLC P. O. Box 13707 New Orleans, LA 70185 504−218−5887 Email: patricia@bollmanfirm.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

Brian C. Roux (See above for address) ATTORNEY TO BE NOTICED

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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 155 of 247

Defendant Malvern C. Burnett TERMINATED: 10/05/2015
Defendant Law Offices of Malvern C. Burnett, A.P.C. TERMINATED: 10/05/2015
Defendant Gulf Coast Immigration Law Center, L.L.C. 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. Buras Law Firm, LLC 301 N. Columbia St. Covington, LA 70433 985−306−1769 Fax: 888−383−4079 Email: DBuras@BurasLawFirm.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 LEAD ATTORNEY ATTORNEY TO BE NOTICED
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
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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 156 of 247

(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

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) ATTORNEY TO BE NOTICED

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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 157 of 247

Lauren Masur Davis Hangartner, Rydberg, Terrell &Hart, LLC One Shell Square 701 Poydras Street Suite 310 New Orleans, LA 70139 504−522−5689 Email: lmasur@hanrylaw.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 Signal International Texas, L.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) ATTORNEY TO BE NOTICED

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)

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 158 of 247
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 JMAssociates, Inc. of Mississippi (13−6219, 14−1818) Consol Defendant Billy R Wilks (13−6219, 14−1818)
Consol Defendant Indo−Amerisoft LLC (13−6221) Consol Defendant Signal International, LLC (13−6219, 13−6221, 14−732, 14−1818)

represented by Kurella Rao #6 Isla Road, Unity Zone Dangriga Belize 501−638−3820 PRO SE
represented by Billy R Wilks 9136 Heather Lane Moss Point, MS 39562 (228) 475−7340 PRO SE
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) ATTORNEY TO BE NOTICED
Dominic Joseph Gianna (See above for address) TERMINATED: 03/19/2014
Elham Rabbani (See above for address) ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 159 of 247

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

Alan Dean Weinberger (See above for address) ATTORNEY TO BE NOTICED

Brian C. Roux (See above for address) ATTORNEY TO BE NOTICED

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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 160 of 247

Consol Defendant
Malvern C. Burnett (13−6219 − Dismissed 10/5/2015, 13−6220, 13−6221, 14−732, 14−1818)

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)

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
Gulf Coast Immigration Law Center, L.L.C. (13−6219 − Dismissed 10/5/2015, 13−6220, 13−6221, 14−732, 14−1818)

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
JMMarine &Industrial, LLC (13−6219, 14−1818)

Consol Defendant
Global Resources, Inc. (13−6219, 13−6220, 13−6221, 14−732, 14−1818)

Consol Defendant

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 161 of 247

Sachin Dewan (13−6219, 13−6220, 13−6221, 14−732, 14−1818)

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) 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 (See above for address) ATTORNEY TO BE NOTICED

Brian C. Roux (See above for address) ATTORNEY TO BE NOTICED

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)

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 162 of 247

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 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) ATTORNEY TO BE NOTICED
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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 163 of 247

Cross Claimant World Marine, LLC
Cross Claimant Signal International, LLC 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) ATTORNEY TO BE NOTICED
Elham Rabbani (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
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) ATTORNEY TO BE NOTICED
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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 164 of 247

Cross Claimant Signal International, Inc.
Cross Claimant Signal International Texas, G.P.

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 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) ATTORNEY TO BE NOTICED
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 Erin Casey Hangartner (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 165 of 247

Cross Claimant
Signal International Texas, L.P. TERMINATED: 01/21/2016

Alan Dean Weinberger (See above for address) ATTORNEY TO BE NOTICED
Brian C. Roux (See above for address) ATTORNEY TO BE NOTICED
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
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) ATTORNEY TO BE NOTICED
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: 04/03/2016 11:37 AM CDT 166 of 247
(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. 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

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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 167 of 247

JMAssociates, Inc. of Mississippi (13−6219)

Cross Defendant
JMMarine &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

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)

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 168 of 247

ATTORNEY TO BE NOTICED

Brian C. Roux (See above for address) ATTORNEY TO BE NOTICED

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

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) ATTORNEY TO BE NOTICED

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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 169 of 247

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 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) ATTORNEY TO BE NOTICED

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 Defendant
Gulf Coast Immigration Law Center, L.L.C.

represented by Timothy W. Cerniglia (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 170 of 247

Cross Claimant Signal International Texas, L.P. TERMINATED: 01/21/2016
Cross Claimant Malvern C. Burnett (13−6219, 13−6220, 13−6221, 14−732, 14−1818)
Cross Claimant

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) ATTORNEY TO BE NOTICED
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
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: 04/03/2016 11:37 AM CDT 171 of 247

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

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

Cross Claimant Sachin Dewan

represented by Stephen H. Shapiro (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Cross Claimant Dewan Consultants Pvt. Ltd.

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) ATTORNEY TO BE NOTICED
Dominic Joseph Gianna (See above for address) TERMINATED: 03/19/2014

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 172 of 247

Cross Defendant
Signal International, LLC (13−6219, 13−6221, 14−732, 14−1818)

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 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) ATTORNEY TO BE NOTICED
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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 173 of 247
(See above for address) ATTORNEY TO BE NOTICED

Date Filed 05/21/2013
05/21/2013 06/13/2013
06/13/2013 06/14/2013 06/17/2013 06/17/2013 06/18/2013

# 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 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: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 174 of 247

06/19/2013 06/21/2013
06/21/2013 06/21/2013
06/21/2013 06/21/2013

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 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)

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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 06/27/2013

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)
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

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07/11/2013 07/11/2013 07/12/2013
07/12/2013 07/12/2013 07/15/2013
07/15/2013
07/15/2013

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)
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,

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07/15/2013 07/15/2013 07/15/2013 07/15/2013 07/18/2013

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 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)

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07/19/2013 07/29/2013
07/29/2013
07/31/2013 08/01/2013 08/01/2013

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 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,

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08/05/2013 08/06/2013
08/06/2013 08/07/2013
08/13/2013
08/14/2013

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 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

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08/27/2013
08/27/2013
08/30/2013 09/16/2013 09/20/2013 09/20/2013 10/03/2013 10/03/2013
10/07/2013

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.] (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

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10/07/2013
10/07/2013
10/09/2013 10/10/2013

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 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)

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10/14/2013 10/14/2013 10/16/2013
10/16/2013 10/17/2013 10/18/2013 10/18/2013
10/23/2013 10/24/2013 10/24/2013 10/25/2013
10/28/2013

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)
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,

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10/28/2013 10/28/2013 10/29/2013 10/31/2013 10/31/2013 10/31/2013 11/01/2013 11/05/2013 11/07/2013 11/07/2013
11/07/2013

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)
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

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11/07/2013 11/08/2013

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 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:

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11/08/2013 11/08/2013 11/08/2013 11/08/2013 11/08/2013
11/08/2013

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 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)

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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, 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)

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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 Attorney Registration Form)(Reference: 2:13−CV−06221)(Grimsal, A.) Modified on 11/12/2013 (gbw, ). (Entered: 11/11/2013)

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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

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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 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)

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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)
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

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11/19/2013 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

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)
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,

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11/22/2013 11/25/2013
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

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 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

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12/04/2013
12/06/2013 12/10/2013 12/10/2013 12/16/2013
12/17/2013 12/17/2013 12/17/2013 12/19/2013

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 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,

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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

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.) 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)

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01/21/2014 01/22/2014 01/22/2014
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

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)
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)

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02/04/2014 02/04/2014
02/05/2014 02/06/2014 02/06/2014 02/06/2014
02/07/2014 02/07/2014 02/10/2014 02/10/2014 02/11/2014

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 (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)

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 197 of 247

02/11/2014 02/11/2014 02/11/2014
02/12/2014 02/12/2014 02/12/2014 02/13/2014 02/13/2014
02/13/2014 02/14/2014

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)
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 JMAssociates, Inc. of Mississippi, JMMarine &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,

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 198 of 247

02/14/2014
02/14/2014
02/17/2014 02/17/2014 02/18/2014
02/18/2014 02/18/2014 02/18/2014 02/18/2014 02/19/2014 02/20/2014

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. (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,

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 199 of 247

02/20/2014
02/20/2014 02/20/2014

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 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)

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 200 of 247

02/21/2014
02/21/2014 02/21/2014 02/24/2014 02/28/2014 02/28/2014 03/03/2014
03/03/2014
03/03/2014

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. 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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 201 of 247

03/03/2014 03/05/2014 03/05/2014
03/05/2014

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 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)

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 202 of 247

03/06/2014 03/06/2014 03/07/2014
03/10/2014 03/11/2014
03/12/2014 03/18/2014 03/18/2014 03/18/2014 03/18/2014

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)
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:

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03/18/2014 03/19/2014 03/19/2014 03/19/2014 03/24/2014
03/31/2014 03/31/2014

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)
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)

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03/31/2014 03/31/2014 04/02/2014 04/02/2014 04/02/2014
04/03/2014 04/03/2014 04/07/2014 04/07/2014 04/07/2014 04/07/2014

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. 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)

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04/11/2014 04/11/2014 04/14/2014 04/14/2014 04/21/2014
04/24/2014 04/24/2014
04/29/2014

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)
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

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05/08/2014
05/08/2014
05/09/2014 05/09/2014 05/14/2014 05/15/2014 05/16/2014 05/16/2014

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 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)

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05/16/2014
05/16/2014
05/20/2014 05/20/2014 05/20/2014 05/20/2014 05/20/2014 05/20/2014

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)
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)

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05/20/2014 05/21/2014
05/21/2014 05/23/2014 05/23/2014 05/23/2014 05/27/2014 05/27/2014 05/28/2014 05/28/2014 05/28/2014

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 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)

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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 07/02/2014

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, 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)

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 210 of 247

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

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 &14−732)(Hangartner, Erin) Modified on 8/1/2014 to remove submission info (bwn). (Entered: 08/01/2014)

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 211 of 247

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

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 this order, as further stated herein. Signed by Judge Susie Morgan on 8/18/2014. (Reference: All Cases) (tsf) (Entered: 08/18/2014)

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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 08/26/2014

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)
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

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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

&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)

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 214 of 247

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:

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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

09/24/2014)
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)), JMAssociates, Inc. of Mississippi, JMMarine &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),

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 217 of 247

10/01/2014 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

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)
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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 218 of 247

10/04/2014
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

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 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)

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10/22/2014 10/22/2014 10/28/2014 10/30/2014 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

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)
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

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 220 of 247

12/31/2014
12/31/2014 12/31/2014 12/31/2014 12/31/2014 01/05/2015 01/06/2015 01/06/2015 01/06/2015

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: 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)

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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. (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)

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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. 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

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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)
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

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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)
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)

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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, 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

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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)
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

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04/16/2015 04/16/2015 04/16/2015
04/23/2015 04/29/2015 04/30/2015 04/30/2015 04/30/2015 04/30/2015
04/30/2015

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)
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

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04/30/2015
04/30/2015 04/30/2015 04/30/2015 04/30/2015 04/30/2015 04/30/2015 05/01/2015 05/04/2015
05/04/2015
05/04/2015

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)
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)

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05/04/2015 05/06/2015 05/08/2015
05/11/2015
05/18/2015 05/18/2015 05/18/2015
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

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)
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.

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05/21/2015 05/21/2015 06/01/2015 06/01/2015 06/02/2015 06/03/2015
06/03/2015
06/03/2015
06/03/2015
06/03/2015
06/03/2015

(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)
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)

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06/04/2015 06/05/2015
06/08/2015 06/08/2015 06/09/2015
06/09/2015 06/09/2015 06/10/2015 06/10/2015 06/11/2015

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 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: 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)
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)

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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 06/16/2015 06/16/2015

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. (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

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06/16/2015
06/16/2015 06/16/2015 06/16/2015 06/16/2015 06/16/2015 06/16/2015 06/16/2015 06/16/2015

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 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)

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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)
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)

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06/17/2015 06/18/2015 06/18/2015
06/18/2015
06/18/2015
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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)
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)

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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 06/22/2015 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)
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

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06/22/2015 06/22/2015
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06/24/2015

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 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)

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06/29/2015

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 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

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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 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: 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)

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07/01/2015 07/01/2015 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

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)
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)

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07/02/2015 07/02/2015 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

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)
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)

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07/03/2015 07/03/2015 07/06/2015 07/06/2015 07/06/2015 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

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)
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)

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07/15/2015 07/16/2015
07/28/2015 07/28/2015 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

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)
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)

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09/10/2015 09/21/2015 09/27/2015 09/28/2015 09/28/2015 09/28/2015 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

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)
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,

Case: 2:13-cv-6218 As of: 04/03/2016 11:37 AM CDT 245 of 247

11/06/2015
12/02/2015
12/14/2015
12/15/2015 12/15/2015 12/18/2015 12/18/2015 12/21/2015 12/22/2015 12/23/2015

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 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, Malvern C. Burnett, Malvern C. Burnett, Gulf Coast Immigration Law Center, L.L.C., 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 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

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12/28/2015 12/28/2015
12/28/2015
12/29/2015 01/20/2016
01/20/2016 01/20/2016
01/21/2016
01/21/2016 01/21/2016 02/01/2016 02/03/2016

Submission, # 9 Proposed Proposed Order)(Reference: 13−6218,13−6219, 13−6220; 13−6221; 14−427, 14−1818)(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, 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,

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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)