| Court: | kywd |
| Docket #: | 1:15-cv-00047 |
| Case Name: | Amtote International Inc. v. Kentucky Downs, LLC et al |
| PACER case #: | 94035 |
| Date filed: | 2015-04-02 |
| Assigned to: | Judge Greg N. Stivers |
| Referred to: | Magistrate Judge H. Brent Brennenstuhl |
| Case Cause: | 28:1332 Diversity Action |
| Nature of Suit: | 190 Contract: Other |
| Jury Demand: | None |
| Jurisdiction: | Diversity |
| Represented Party | Attorney & Contact Info |
| Amtote International Inc. Plaintiff |
James M. Hinshaw Matthew J. Frontini Maxwell R. Morgan Nathaniel B. Lipkus Reva D. Campbell Timothy H. Gilbert |
| Kentucky Downs, LLC Defendant |
Jay E. Ingle Mary Elisabeth Naumann William A. Hoskins |
| Corey S. Johnsen Defendant in both his individual and corporate capacities |
Jay E. Ingle Mary Elisabeth Naumann William A. Hoskins |
| Nicholas Hughes Defendant in both his individual and corporate capacities |
Jay E. Ingle Mary Elisabeth Naumann William A. Hoskins |
| Rayford T. Reid Defendant in both his individual and corporate capacities |
Jay E. Ingle Mary Elisabeth Naumann William A. Hoskins |
| Encore Gaming, LLC Defendant |
Jay E. Ingle Mary Elisabeth Naumann William A. Hoskins |
| Date Filed | Document # | Attachment # | Short Description | Long Description | Upload date | SHA1 hash |
| 2015-04-03 | 1 | 0 | COMPLAINT against Encore Gaming, LLC, Nicholas Hughes, Corey S. Johnsen, Kentucky Downs, LLC, Rayford T. Reid Filing fee $ 400, receipt number 0644-1985444, filed by Amtote International Inc.. (Attachments: # 1 Verification, # 2 Exhibit A - Filed Under Seal, # 3 Exhibit B - Filed Under Seal, # 4 Exhibit C - Filed Under Seal) (DJT) (Additional attachment(s) added on 4/3/2015: # 5 Cover Sheet) (DJT). (Entered: 04/03/2015) | |||
| 2015-04-03 | 2 | 0 | Case Assignment (Random Selection): Case Assigned to Judge Greg N. Stivers. (DJT) (Entered: 04/03/2015) | |||
| 2015-04-03 | 3 | 0 | Corporate Disclosure Statement identifying Corporate Parent TSG Developments Inc. for Amtote International Inc.. (DJT) (Entered: 04/03/2015) | |||
| 2015-04-03 | 4 | 0 | Summons Issued as to Encore Gaming, LLC, Nicholas Hughes, Corey S. Johnsen, Kentucky Downs, LLC, Rayford T. Reid. Counsel for Plaintiff is responsible for printing and serving the attached issued summons(es).ATTESTED COPY OF COMPLAINT EMAILED TO COUNSEL BY CLERK. (Attachments: # 1 Summons as to Corey Johnsen, individually, # 2 Summons as to Encore Gaming, LLC, # 3 Summons as to Kentucky Downs, LLC, # 4 Summons as to Nicholas Hughes, as GM and SVP of Kentucky Downs, LLC, # 5 Summons as to Nicholas Hughes, individually, # 6 Summons as to Rayford Reid, as officer of Kentucky Downs, # 7 Summons as to Rayford Reid, as President of Encore Gaming, LLC, # 8 Summons as to Rayford Reid, individually) (DJT) (Entered: 04/03/2015) | |||
| 2015-04-03 | 5 | 0 | MOTION to Seal Document 1 Complaint, by Plaintiff Amtote International Inc. Responses due by 4/27/2015 (Attachments: # 1 Proposed Order) (Campbell, Reva) (Entered: 04/03/2015) | |||
| 2015-04-03 | 6 | 0 | Sealed Document re 1 , 5 (Attachments: # 1 Exhibit A - Totalisator Services Agreement, # 2 Exhibit B - Amendment No. 1 to Totalisator Services Agreement, # 3 Exhibit C - Amendment No. 2 to Totalisator Services Agreement) (Campbell, Reva) (Entered: 04/03/2015) | |||
| 2015-04-03 | 7 | 0 | TEXT ORDER by Judge Greg N. Stivers (EBOC) on 04/03/2015; Referring Case to Magistrate Judge H. Brent Brennenstuhl pursuant to 28:636(b)(1)(A) for disposition of all non-dispositive motions. This Notice of Electronic Filing is the Official ORDER for this entry. No document is attached.cc: Counsel; KL (TJD) (Entered: 04/03/2015) | |||
| 2015-04-07 | 8 | 0 | MOTION for James M. Hinshaw to Appear Pro Hac Vice Filing fee $ 65, receipt number 0644-1987340.by Plaintiff Amtote International Inc. Responses due by 5/1/2015 (Attachments: # 1 Exhibit Mr. Hinshaw's Electronic Filing Registration Form, # 2 Affidavit, # 3 Affidavit, # 4 Proposed Order) (Campbell, Reva) (Entered: 04/07/2015) | |||
| 2015-04-09 | 9 | 0 | ORDER granting 8 Motion to Appear Pro Hac Vice as to James M. Hinshaw. Signed by Magistrate Judge H. Brent Brennenstuhl on 4/8/2015. cc: Counsel (CDR) (Entered: 04/09/2015) | |||
| 2015-04-10 | 10 | 0 | MOTION for Timothy H. Gilbert to Appear Pro Hac Vice Filing fee $ 65, receipt number 0644-1989897.by Plaintiff Amtote International Inc. Responses due by 5/4/2015 (Attachments: # 1 Exhibit Affidavit of Reva Campbell, # 2 Exhibit Affidavit of Timothy Gilbert, # 3 Exhibit 1 - Gilbert's Electronic Filing Registration Form, # 4 Proposed Order) (Campbell, Reva) (Entered: 04/10/2015) | |||
| 2015-04-13 | 11 | 0 | MOTION to Expedite Discovery by Plaintiff Amtote International Inc. Responses due by 5/7/2015 (Attachments: # 1 Exhibit A - Discovery Requests and Deposition Notices, # 2 Exhibit B - Proposed Agreed Protective Order, # 3 Proposed Order) (Campbell, Reva) (Entered: 04/13/2015) | |||
| 2015-04-13 | 12 | 0 | Sealed Document re 11 (Campbell, Reva) (Entered: 04/13/2015) | |||
| 2015-04-14 | 13 | 0 | ORDER granting 10 Motion to Appear Pro Hac Vice as to Timothy H. Gilbert. Signed by Magistrate Judge H. Brent Brennenstuhl on 4/13/2015. cc: Counsel (CDR) (Entered: 04/14/2015) | |||
| 2015-04-20 | 14 | 0 | Return of Service Executed/Unexecuted as to Kentucky Downs, LLC. (Attachments: # 1 Receipt Certified Mail - Return Receipt) (Campbell, Reva) (Entered: 04/20/2015) | |||
| 2015-04-21 | 15 | 0 | MOTION for Preliminary Injunction by Plaintiff Amtote International Inc. Responses due by 5/15/2015 (Attachments: # 1 Memorandum in Support, # 2 Affidavit Steve Keech - Filed Under Seal, # 3 Affidavit John O'Neal - Filed Under Seal, # 4 Proposed Order) (Campbell, Reva) (Entered: 04/21/2015) | |||
| 2015-04-21 | 16 | 0 | MOTION to Seal Document 15 MOTION for Preliminary Injunction by Plaintiff Amtote International Inc. Responses due by 5/15/2015 (Attachments: # 1 Proposed Order) (Campbell, Reva) (Entered: 04/21/2015) | |||
| 2015-04-21 | 17 | 0 | Sealed Document re 16 , 15 (Attachments: # 1 Affidavit Steve Keech, # 2 Exhibit A to Affidavit of Steve Keech, # 3 Exhibit B to Affidavit of Steve Keech, # 4 Exhibit C to Affidavit of Steve Keech, # 5 Exhibit D to Affidavit of Steve Keech, # 6 Exhibit E to Affidavit of Steve Keech, # 7 Exhibit F to Affidavit of Steve Keech, # 8 Exhibit G to Affidavit of Steve Keech, # 9 Exhibit H to Affidavit of Steve Keech, # 10 Exhibit I to Affidavit of Steve Keech, # 11 Affidavit John O'Neal) (Campbell, Reva) (Entered: 04/21/2015) | |||
| 2015-04-27 | 18 | 0 | NOTICE FROM SECRETARY OF STATE OF SERVICE OF SUMMONS Returned Executed. Corey S. Johnsen served on 4/18/2015, answer due 5/11/2015. (JWM) (Entered: 04/28/2015) | |||
| 2015-04-28 | 19 | 0 | MOTION to Expedite Scheduling Conference by Plaintiff Amtote International Inc. Responses due by 5/22/2015 (Attachments: # 1 Exhibit A - E-mail between counsel, # 2 Proposed Order) (Campbell, Reva) (Entered: 04/28/2015) | |||
| 2015-04-30 | 20 | 0 | ORDER granting 5 Motion to Seal Document 6 Sealed Document,; Signed by Judge Greg N. Stivers on 4/30/15: Plaintiff's Motion to File Exhibits under Seal is and shall be GRANTED. DN 5 granted. cc : Counsel (DJT) (Entered: 04/30/2015) | |||
| 2015-04-30 | 21 | 0 | ORDER by Judge Greg N. Stivers on 4/30/15: Telephonic Conference set for 5/5/2015 at 3:00 PM before Judge Greg N. Stivers. cc:counsel, William Hoskins, Mary Beth Naumann (DJT) (Entered: 04/30/2015) | |||
| 2015-05-01 | 22 | 0 | MOTION for Extension of Time to File Answer re 1 Complaint, Served Defendant's Motion for Extension of Time to Respond to Plaintiff's Complaint by Defendants Encore Gaming, LLC, Nicholas Hughes, Corey S. Johnsen, Kentucky Downs, LLC Responses due by 5/11/2015 (Naumann, Mary) (Additional attachment(s) added on 5/4/2015: # 1 Proposed Order) (JBMS). (Entered: 05/01/2015) | |||
| 2015-05-01 | 23 | 0 | Proposed Order by Encore Gaming, LLC, Nicholas Hughes, Corey S. Johnsen, Kentucky Downs, LLC. (Naumann, Mary) (Entered: 05/01/2015) | |||
| 2015-05-04 | 24 | 0 | RESPONSE to Motion re 19 MOTION to Expedite Scheduling Conference filed by Encore Gaming, LLC, Nicholas Hughes, Corey S. Johnsen, Kentucky Downs, LLC. Replies due by 5/21/2015. (Attachments: # 1 Proposed Order) (Naumann, Mary) (Entered: 05/04/2015) | |||
| 2015-05-05 | 25 | 0 | MOTION for Nathaniel B. Lipkus to Appear Pro Hac Vice Filing fee $ 65, receipt number 0644-2004322.by Plaintiff Amtote International Inc. Responses due by 5/29/2015 (Attachments: # 1 Affidavit of Reva Campbell, # 2 Affidavit of Nathaniel Lipkus, # 3 Receipt Electronic Filing Attorney Registration Form, # 4 Proposed Order) (Campbell, Reva) (Entered: 05/05/2015) | |||
| 2015-05-05 | 26 | 0 | MOTION for Maxwell R. Morgan to Appear Pro Hac Vice Filing fee $ 65, receipt number 0644-2004408.by Plaintiff Amtote International Inc. Responses due by 5/29/2015 (Attachments: # 1 Affidavit of Reva Campbell, # 2 Affidavit of Maxwell Morgan, # 3 Receipt Electronic Filing Attorney Registration Form, # 4 Proposed Order) (Campbell, Reva) (Entered: 05/05/2015) | |||
| 2015-05-04 | 27 | 0 | SUMMONS Returned Executed by Amtote International Inc. via Secretary of state. Defendant Corey S. Johnsen served on 4/20/2015, answer due 5/11/2015. (JBM) (Entered: 05/05/2015) | |||
| 2015-05-05 | 28 | 0 | MOTION for Matthew J. Frontini to Appear Pro Hac Vice Filing fee $ 65, receipt number 0644-2004449.by Plaintiff Amtote International Inc. Responses due by 5/29/2015 (Attachments: # 1 Affidavit of Reva Campbell, # 2 Affidavit of Matthew Frontini, # 3 Receipt Electronic Filing Attorney Registration Form, # 4 Proposed Order) (Campbell, Reva) (Entered: 05/05/2015) | |||
| 2015-05-07 | 29 | 0 | ORDER by Magistrate Judge H. Brent Brennenstuhl. 28 Motion for Attorney Matthew J. Frontini to Appear Pro Hac Vice on behalf of Plaintiff, AmTote International, Inc. is granted. cc: Counsel, Matthew J. Frontini, Jay E. Ingle, Maxwell R. Morgan, Nathaniel B. Lipkus(JWM) Modified to edit distribution on 5/7/2015 (JWM). (Entered: 05/07/2015) | |||
| 2015-05-07 | 30 | 0 | ORDER by Magistrate Judge H. Brent Brennenstuhl. 25 Motion for Attorney Nathaniel B. Lipkus to Appear Pro Hac Vice on behalf of Plaintiff, AmTote International, Inc. is granted. cc: Counsel, Nathaniel B. Lipkus, Jay E. Ingle, Matthew J. Frontini, Maxwell R. Morgan(JWM) (Entered: 05/07/2015) | |||
| 2015-05-07 | 31 | 0 | ORDER by Magistrate Judge H. Brent Brennenstuhl. 26 Motion for Attorney Maxwell R. Morgan to Appear Pro Hac Vice on behalf of Plaintiff, AmTote International, Inc. is granted. cc: Counsel, Maxwell R. Morgan, Nathaniel B. Lipkus, Matthew J. Frontini, Jay E. Ingle(JWM) (Entered: 05/07/2015) | |||
| 2015-05-08 | 32 | 0 | ORDER for Proceedings held before Judge Greg N. Stivers: Telephone Conference held on 5/5/2015. Served Defendants' 22 Motion for Extension of Time to Answer re 1 Complaint is granted. Served Defendants are granted until 5/19/2015 to respond to Complaint. Parties directed to try to reach agreement regarding Plaintiff's Motion for Expedited Discovery. Response dates for 11 Motion for Expedited Discovery and 15 Motion for Preliminary Injunction are vacated. Telephone Conference set for 5/20/2015 03:00 PM CDT/4:00 PM EDT before Judge Greg N. Stivers. Counsel for the parties are directed to connect to the conference by dialing the Toll Free Meeting Number 888-808-6929 and entering the Access Code 9986721#. cc:counsel (JWM) (Entered: 05/08/2015) | |||
| 2015-05-19 | 33 | 0 | Sealed Document pursuant to 20 Order, re 11 (Attachments: # 1 Exhibit 1 - KHRC 9-25-14 Minutes of Meeting, # 2 Exhibit 2 - KHRC 4-2-14 Conditions, # 3 Exhibit 3 - KHRC 3-23-15 Conditions, # 4 Exhibit 4 - RaceTech Agreement, # 5 Exhibit 5 - 1st Amendment to Agreement, # 6 Exhibit 6 - 8-1-14 Letter from Cella to Johnsen, # 7 Exhibit 7 - 2-19-15 Letter from Cella to Johnsen, # 8 Exhibit 8 - Colorado case cited, # 9 Exhibit 9 - Secretary of State Results re Encore Gaming LLC, # 10 Exhibit 10 - Encore, FAQS, # 11 Exhibit 11 - KHRC, Totalizator Standards, # 12 Exhibit 12 - TESS re Instant Racing, # 13 Proposed Order) (Naumann, Mary) Modified to link to DN 20 for authority purposes on 5/20/2015 (CDRS). (Entered: 05/19/2015) | |||
| 2015-05-19 | 34 | 0 | SEALED MOTION pursuant to 20 Order, re 1 Complaint, by Encore Gaming, LLC, Nicholas Hughes, Corey S. Johnsen, Kentucky Downs, LLC, Rayford T. Reid (Attachments: # 1 Memorandum in Support of Motion to Dismiss, # 2 Exhibit 1 - 9-25-14 KHRC Minutes of Meeting, # 3 Exhibit 2 - 4-2-14 KHRC Conditions, # 4 Exhibit 3 - 3-23-15 KHRC Conditions, # 5 Exhibit 4 - RaceTech Agreement, # 6 Exhibit 5 - 1st Amendment to Agreement, # 7 Exhibit 6 - 8-1-14 Letter from Cella to Johnsen, # 8 Exhibit 7 - 2-19-15 Letter from Cella to Johnsen, # 9 Exhibit 8 - Colorado Case Cite, # 10 Exhibit 9 - Secretary of State Results re Encore Gaming, LLC, # 11 Exhibit 10 - Encore, FAQS, # 12 Exhibit 11 - KHRC, Totalizator Standards, # 13 Exhibit 12 - TESS re Instant Racing, # 14 Proposed Order) (Naumann, Mary) Modified to link to DN 20 for authority purposes on 5/20/2015 (CDRS). (Entered: 05/19/2015) | |||
| 2015-05-19 | 35 | 0 | CERTIFICATE OF SERVICE by Encore Gaming, LLC, Nicholas Hughes, Corey S. Johnsen, Kentucky Downs, LLC re 33 Sealed Document,, Corrected Certificate of Service (Naumann, Mary) (Entered: 05/19/2015) | |||
| 2015-05-19 | 36 | 0 | NOTICE of Supplementation by Amtote International Inc. re 11 MOTION to Expedite Discovery (Attachments: # 1 Exhibit A - April 27, 2015 Email, # 2 Exhibit B - April 29, 2015 Email, # 3 Exhibit C - April 30, 2015 Email, # 4 Exhibit D - May 8, 2015 Email, # 5 Exhibit E - May 8, 2015 with proposed Protective Order, # 6 Exhibit F - May 11, 2015 Email, # 7 Exhibit G - May 11, 2015 with narrowed discovery requests, # 8 Exhibit H - revised Interrogatories to Encore, # 9 Exhibit I - revised Interrogatories to Kentucky Downs, # 10 Exhibit J - revised Interrogatories to Individual Defendants, # 11 Exhibit K - revised document requests, # 12 Exhibit L - May 14, 2015 Email, # 13 Exhibit M - May 16, 2015 Email, # 14 Exhibit N - second revised document requests, # 15 Exhibit O - second revised Interrogatories to Encore, # 16 Exhibit P - second revised Interrogatories to Kentucky Downs, # 17 Exhibit Q - second revised Interrogatories to Individual Defendants, # 18 Exhibit R - revised 30(b)(6) Deposition Notice to Encore, # 19 Exhibit S - revised 30(b)(6) Deposition Notice to Kentucky Downs, # 20 Exhibit T - proposed Protective Order) (Campbell, Reva) (Entered: 05/19/2015) | |||
| 2015-05-20 | 37 | 0 | Corporate Disclosure Statement by Kentucky Downs, LLC. (Naumann, Mary) (Entered: 05/20/2015) | |||
| 2015-05-20 | 38 | 0 | Corporate Disclosure Statement by Encore Gaming, LLC. (Naumann, Mary) (Entered: 05/20/2015) | |||
| 2015-05-20 | 39 | 0 | RESPONSE to Motion re 11 MOTION to Expedite Discovery Redacted Public Version filed by Encore Gaming, LLC, Nicholas Hughes, Corey S. Johnsen, Kentucky Downs, LLC. Replies due by 6/8/2015. (Attachments: # 1 Exhibit 1 - 9-25-14 KHRC Minutes of Meeting, # 2 Exhibit 2 - 4-2-14 KHRC Conditions, # 3 Exhibit 3 - 3-23-15 KHRC Conditions, # 4 Exhibit 4 - RaceTech Agreement - Filed Under Seal, # 5 Exhibit 5 - 1st Amendment to Agreement - Filed Under Seal, # 6 Exhibit 6 - 8-1-14 Letter from Cella to Johnsen - Filed Under Seal, # 7 Exhibit 7 - 2-19-15 Letter from Cella to Johnsen - Filed Under Seal, # 8 Exhibit 8 - Colorado Case Cite, # 9 Exhibit 9 - Secretary of State Results re Encore Gaming, LLC, # 10 Exhibit 10 - Encore, FAQS, # 11 Exhibit 11 - KHRC, Totalizator Standards, # 12 Exhibit 12 - TESS re Instant Racing, # 13 Proposed Order) (Naumann, Mary) (Entered: 05/20/2015) | |||
| 2015-05-20 | 40 | 0 | MOTION to Dismiss Plaintiff's Complaint by Defendants Encore Gaming, LLC, Nicholas Hughes, Corey S. Johnsen, Kentucky Downs, LLC, Rayford T. Reid Responses due by 6/15/2015 (Attachments: # 1 Memorandum in Support, # 2 Exhibit 1 - 9-25-14 KHRC Minutes of Meeting, # 3 Exhibit 2 - 4-2-14 KHRC Conditions, # 4 Exhibit 3 - 3-23-15 KHRC Conditions, # 5 Exhibit 4 - RaceTech Agreement - Filed Under Seal, # 6 Exhibit 5 - 1st Amendment to Agreement - Filed Under Seal, # 7 Exhibit 6 - 8-1-14 Letter from Cella to Johnsen - Filed Under Seal, # 8 Exhibit 7 - 2-19-15 Letter from Cella to Johnsen - Filed Under Seal, # 9 Exhibit 8 - Colorado Case Cite, # 10 Exhibit 9 - Secretary of State Results re Encore Gaming, LLC, # 11 Exhibit 10 - Encore, FAQS, # 12 Exhibit 11 - KHRC, Totalizator Standards, # 13 Exhibit 12 - TESS re Instant Racing, # 14 Proposed Order) (Naumann, Mary) (Entered: 05/20/2015) | |||
| 2015-05-20 | 41 | 0 | MOTION to Strike and Substitute 1 Complaint, 15 MOTION for Preliminary Injunction , 11 MOTION to Expedite Discovery. Document or Part to be Stricken and/or Substituted: 15-1 by Plaintiff Amtote International Inc. Responses due by 6/8/2015 (Attachments: # 1 Exhibit A - Verified Complaint for Injunctive Relief, # 2 Exhibit B - Plaintiff's Motion for Expedited Discovery, # 3 Exhibit C - Plaintiff's Memorandum of Law in Support of its Motion for Preliminary Injunction, # 4 Proposed Order) (Campbell, Reva) (Entered: 05/20/2015) | |||
| 2015-05-26 | 42 | 0 | ORDER for proceedings held before Judge Greg N. Stivers: Telephone Conference held on 5/20/2015. Plaintiff is directed to disclose its trade secrets with reasonable particularity to Defendants on or before 5/26/2015. Plaintiff is further directed to file its response to Defendants' Motion to Dismiss (DN 40 ) on or before 6/2/2015. Telephone Conference set for 6/4/2015 at 1:00 PM CT/2:00 PM ET before Judge Greg N. Stivers. Counsel for the parties are directed to connect to the conference by dialing the Toll Free Meeting Number 888-808-6929 and entering Access Code 9986721#. The deadline to respond to the Motion for Preliminary Injunction (DN 15 ) will be set at the next telephone conference. cc: Counsel (CDR) (Entered: 05/26/2015) |