Professional Documents
Culture Documents
3 8/10/10 9:36 PM
ECF, RELATED
Footbridge Limited Trust and OHP Opportunity Limited Trust v. Date Filed: 01/15/2010
Countrywide Financial Corp. et al Jury Demand: Plaintiff
Assigned to: Judge P. Kevin Castel Nature of Suit: 850
Related Case: 1:09-cv-04050-PKC Securities/Commodities
Cause: 15:78m(a) Securities Exchange Act Jurisdiction: Federal Question
Plaintiff
Footbridge Limited Trust and OHP represented by Daniel Lawrence Brockett
Opportunity Limited Trust Quinn Emanuel Urquhart & Sullivan, LLP
(NYC)
51 Madison Avenue
New York, NY 10010
212 849 7000
Fax: 212 849 7100
Email: danbrockett@quinnemanuel.com
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
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ATTORNEY TO BE NOTICED
V.
Defendant
Countrywide Financial Corp. represented by Mitchell A. Lowenthal
Cleary Gottlieb Steen & Hamilton,
LLP(NYC)
One Liberty Plaza
New York, NY 10006
212-225-2000
Fax: 212-225-3499
Email: maofiling@cgsh.com
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
ATTORNEY TO BE NOTICED
Defendant
Countrywide Securities Corp. represented by Mitchell A. Lowenthal
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Defendant
Countrywide Home Loans, Inc. represented by Mitchell A. Lowenthal
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Defendant
Stanford L. Kurland represented by Christopher G. Caldwell
Caldwell, Leslie & Proctor PC
1000 Wilshire Blvd, Suite 600
Los Angeles, CA 90017
(213)-629-9040
Fax: (213)-629-9022
Email: caldwell@caldwell-leslie.com
PRO HAC VICE
ATTORNEY TO BE NOTICED
David C. Codell
Caldwell Leslie & Proctor, P.e.
1000 Wilshire Boulevard, Suite 600
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Eric S. Pettit
Caldwell, Leslie & Proctor PC
1000 Wilshire Blvd, Suite 600
Los Angeles, CA 90017
(213)-629-9040
Fax: (213)-629-9022
Email: pettit@caldwell-leslie.com
PRO HAC VICE
ATTORNEY TO BE NOTICED
Keara M. Gordon
DLA Piper US LLP (NY)
1251 Avenue of the Americas
New York, NY 10020
(212)-335-4632
Fax: (212)-884-8632
Email: keara.gordon@dlapiper.com
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
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Jeffrey B Coopersmith
DLA Piper LLP (Us)
701 Fifth Avenue, Suite 7000
Seattle, WA 98104
(206)-839-4847
Fax: (206)-839-4801
Email: jeff.coopersmith@dlapiper.com
PRO HAC VICE
ATTORNEY TO BE NOTICED
Nicolas Morgan
DLA Piper US L.L.P. (LAng)
1999 Avenue of the Americas
Suite 400
Los Angeles, CA 90067
(310) 595-3000 x3146
Fax: (310) 595-3446
Email: nicolas.morgan@dlapiper.com
PRO HAC VICE
ATTORNEY TO BE NOTICED
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Fax: (202)-373-6001
Email: boyd.cloern@bingham.com
LEAD ATTORNEY
PRO HAC VICE
ATTORNEY TO BE NOTICED
Daniel F. Mitry
Bingham McCutchen LLP (NYC)
399 Park Avenue
New York, NY 10022
(212) 705-7818
Fax: (212) 752-5378
Email: daniel.mitry@bingham.com
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Boyd Cloern
(See above for address)
PRO HAC VICE
ATTORNEY TO BE NOTICED
Defendant
BAC Home Loans Servicing, L.P.
03/02/2010 CASHIERS OFFICE REMARK on 9 Motion to Appear Pro Hac Vice, 10 Motion to
Appear Pro Hac Vice, 8 Motion to Appear Pro Hac Vice in the amount of $75.00, paid
on 02/23/2010, Receipt Number 895350. (jd) (Entered: 03/02/2010)
03/02/2010 CASHIERS OFFICE REMARK on 10 Motion to Appear Pro Hac Vice in the amount
of $50.00, paid on 02/23/2010, Receipt Number 895376. (jd) (Entered: 03/02/2010)
03/02/2010 11 ORDER FOR ADMISSION PRO HAC VICE ON WRITTEN MOTION. ORDER
granting 9 Motion for Eric S. Pettit to Appear Pro Hac Vice for defendant Stanford L.
Kurland. (Signed by Judge P. Kevin Castel on 3/2/10) (db) (Entered: 03/02/2010)
03/02/2010 12 ORDER FOR ADMISSION PRO HAC VICE ON WRITTEN MOTION. ORDER
granting 8 Motion for Christopher G. Caldwell to Appear Pro Hac Vice for defendant
Stanford L. Kurland. (Signed by Judge P. Kevin Castel on 3/2/10) (db) (Entered:
03/02/2010)
03/04/2010 14 NOTICE OF APPEARANCE by Daniel F. Mitry on behalf of David A. Spector
(Mitry, Daniel) (Entered: 03/04/2010)
03/04/2010 15 ORDER granting 10 Motion for Marshall M. Searcy III to Appear Pro Hac Vice. So
Ordered. (Signed by Judge P. Kevin Castel on 3/3/2010) (js) (Entered: 03/04/2010)
03/04/2010 16 MOTION for Leiv Blad to Appear Pro Hac Vice. Document filed by David A.
Spector.(mro) (Entered: 03/05/2010)
03/04/2010 17 MOTION for Boyd Cloern to Appear Pro Hac Vice. Document filed by David A.
Spector.(mro) (Entered: 03/05/2010)
03/05/2010 18 ORDER granting 17 Motion for Boyd Cloern to Appear Pro Hac Vice. So Ordered.
(Signed by Judge P. Kevin Castel on 3/5/2010) (js) (Entered: 03/05/2010)
03/05/2010 19 ORDER granting 16 Motion for Leiv Blad to Appear Pro Hac Vice. So Ordered.
(Signed by Judge P. Kevin Castel on 3/5/2010) (js) (Entered: 03/05/2010)
03/08/2010 20 ORDER FOR ADMISSION PRO HAC VICE ON WRITTEN MOTION granting 13
Motion for David C. Codell to Appear Pro Hac Vice. David C. Codell, is admitted to
practice pro hac vice as counsel for Defendant Stanford L. Kurland in this action.
(Signed by Judge P. Kevin Castel on 3/8/2010) (tro) (Entered: 03/08/2010)
03/09/2010 CASHIERS OFFICE REMARK on 17 Motion to Appear Pro Hac Vice, 16 Motion to
Appear Pro Hac Vice in the amount of $50.00, paid on 03/04/2010, Receipt Number
895883. (jd) (Entered: 03/09/2010)
03/09/2010 21 NOTICE OF APPEARANCE by Mitchell A. Lowenthal on behalf of Countrywide
Financial Corp., Countrywide Securities Corp., Countrywide Home Loans, Inc.,
CWabs, Inc. (Lowenthal, Mitchell) (Entered: 03/09/2010)
03/09/2010 22 RULE 7.1 CORPORATE DISCLOSURE STATEMENT. Identifying Bank of
America Corporation as Corporate Parent. Document filed by Countrywide Financial
Corp., Countrywide Securities Corp., Countrywide Home Loans, Inc., CWabs,
Inc..(Lowenthal, Mitchell) (Entered: 03/09/2010)
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made by Mail. Document filed by Footbridge Limited Trust and OHP Opportunity
Limited Trust. (Burnett, David) (Entered: 03/17/2010)
03/19/2010 34 NOTICE OF CHANGE OF ADDRESS by Boyd Cloern on behalf of David A.
Spector. New Address: Bingham McCutchen LLP, 2020 K Street, NW, Washington,
DC, USA 20006, 202-373-6000. (Cloern, Boyd) (Entered: 03/19/2010)
03/31/2010 35 CIVIL CASE MANAGEMENT PLAN AND SCHEDULING ORDER REGARDING
STATUTES OF LIMITATIONIREPOSE DEFENSES: Initial document requests and
initial interrogatories regarding statutes of limitation/repose defenses shall be served
by April 2, 2010. Responses and production in connection with the initial document
requests and initial interrogatories shall be served by April 20, 2010. All discovery,
including written discovery and depositions, regarding statutes of limitation/repose
defenses shall be completed by: Defendants' proposal: June 15, 2010. Defendants'
motion for summary judgment regarding statutes of limitation/repose defenses shall be
served by: Defendants' proposal: July 5, 2010. Plaintiffs' opposition to summary
judgment shall be served by: Defendants' proposal: July 19, 2010. Defendants' reply
shall be served by: Defendants' proposal: August 2, 2010. Case Management
Conference set for 9/3/2010 at 10:30 AM before Judge P. Kevin Castel. (Signed by
Judge P. Kevin Castel on 3/31/2010) (tve) (Entered: 03/31/2010)
04/01/2010 36 MOTION for Shirli Fabbri Weiss, David Priebe, Nicolas Morgan and Jeff
Coopersmith to Appear Pro Hac Vice. Document filed by Eric P. Sieracki.(mro)
(Entered: 04/02/2010)
04/06/2010 37 ORDER granting 36 Motion for Shirli Fabbri Weiss, David Priebe, Nicolas Morgan
and Jeff Coopersmith to Appear Pro Hac Vice for Eric P. Sieracki. (Signed by Judge
P. Kevin Castel on 4/6/2010) (jmi) (Entered: 04/06/2010)
04/14/2010 CASHIERS OFFICE REMARK on 36 Motion to Appear Pro Hac Vice in the amount
of $100.00, paid on 04/01/2010, Receipt Number 899363. (jd) (Entered: 04/14/2010)
05/05/2010 38 ORDER that Daniel Brockett is directed to contact defense counsel forthwith to
arrange a face-to-face, meet, and confer session for no less than one hour in good faith
attempt to resolve or narrow any and all outstanding disputes, and as further set forth
in this document. The Joint Letter is due 5/12/10. ( Status Report/letter due by
5/12/2010.) (Signed by Judge P. Kevin Castel on 4/5/10) (cd) (Entered: 05/05/2010)
05/18/2010 39 ADDENDUM ORDER REGARDING THE CONFIDENTIALITY OF
DOCUMENTS AND INFORMATION: This Addendum Order is an integral part of
an Order entered today governing the confidentiality of documents and other things.
Notwithstanding any other provision in the Order or agreement of the parties, no
document may be filed under seal with the Clerk of Court without further Order of
this Court entered upon an application addressed to the specific document or
documents sought to be sealed; such application shall be made accompanied by
affidavit(s) or declaration(s) and a memorandum of law, demonstrating the standards
for sealing have been met. Without further application to the Court, a party may make
the redactions authorized by Rule 5.2(a), F.R.C.P, subject to the limitations and
procedures set forth in other subdivisions of the Rule. (Signed by Judge P. Kevin
Castel on 5/18/2010) (tro) (Entered: 05/19/2010)
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05/18/2010 40 ENDORSED LETTER addressed to Judge P. Kevin Castel from Meredith E. Kotler
(Counsel for Defendants) and Daniel L. Brockett (Counsel for Plaintiff) dated
5/12/2010 re: Counsel submit this joint letter to notify the Court that on 5/6/2010 they
participated face-to-face, in a meet and confer session, at Plaintiffs' counsel's offices,
for over one hour in a good faith attempt to resolve or narrow any and all outstanding
discovery disputes. ENDORSEMENT: The discovery sought by the plaintiffs is
unnecessary to the targeted and limited discovery in this phase of the case. See Lampf.
et al. v. Gilbertson, 501 US 358 (1991). Defendants are required to produce any
document reflecting a communication between any defendant and any plaintiff during
the relevant time period; to the extent they have not already done so. Plaintiffs'
application denied without prejudice. (Signed by Judge P. Kevin Castel on 5/18/2010)
(tro) (Entered: 05/19/2010)
06/28/2010 41 ENDORSED LETTER addressed to Judge P. Kevin Castel from Meredith E. Kotler
dated 6/25/2010 re: Requesting that the Court modify the Case Management Plan to
provide that Defendants' summary judgment motion shall be filed July 12, 2010;
Plaintiffs' opposition shall be filed August 2, 2010; and Defendants' reply shall be
filed August 16, 2010. ENDORSEMENT: Application granted. (Signed by Judge P.
Kevin Castel on 6/25/2010) (jpo) (Entered: 06/28/2010)
07/12/2010 42 JOINT MOTION for Summary Judgment /Notice of Joint Motion for Summary
Judgment, dated July 12, 2010. Document filed by Stanford L. Kurland, Eric P.
Sieracki, David A. Spector, Bank of America Corp., BAC Home Loans Servicing,
L.P., Countrywide Financial Corp., Countrywide Securities Corp., Countrywide Home
Loans, Inc., CWabs, Inc..(Lowenthal, Mitchell) (Entered: 07/12/2010)
07/12/2010 43 JOINT MEMORANDUM OF LAW in Support re: 42 JOINT MOTION for Summary
Judgment /Notice of Joint Motion for Summary Judgment, dated July 12, 2010..
Document filed by Stanford L. Kurland, Eric P. Sieracki, David A. Spector, Bank of
America Corp., BAC Home Loans Servicing, L.P., Countrywide Financial Corp.,
Countrywide Securities Corp., Countrywide Home Loans, Inc., CWabs, Inc..
(Attachments: # 1 Annex A)(Lowenthal, Mitchell) (Entered: 07/12/2010)
07/12/2010 44 RULE 56.1 STATEMENT. Document filed by Stanford L. Kurland, Eric P. Sieracki,
David A. Spector, Bank of America Corp., BAC Home Loans Servicing, L.P.,
Countrywide Financial Corp., Countrywide Securities Corp., Countrywide Home
Loans, Inc., CWabs, Inc.. (Lowenthal, Mitchell) (Entered: 07/12/2010)
07/12/2010 45 DECLARATION of Jared Gerber, dated July 12, 2010 in Support re: 42 JOINT
MOTION for Summary Judgment /Notice of Joint Motion for Summary Judgment,
dated July 12, 2010.. Document filed by Stanford L. Kurland, Eric P. Sieracki, David
A. Spector, Bank of America Corp., BAC Home Loans Servicing, L.P., Countrywide
Financial Corp., Countrywide Securities Corp., Countrywide Home Loans, Inc.,
CWabs, Inc.. (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, # 15 Exhibit O, # 16
Exhibit P, # 17 Exhibit Q, # 18 Exhibit R, # 19 Exhibit S, # 20 Exhibit T, # 21 Exhibit
U, # 22 Exhibit V, # 23 Exhibit W, # 24 Exhibit X, # 25 Exhibit Y, # 26 Exhibit Z, #
27 Exhibit AA, # 28 Exhibit BB, # 29 Exhibit CC, # 30 Exhibit DD, # 31 Exhibit EE,
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# 32 Exhibit FF, # 33 Exhibit GG, # 34 Exhibit HH, # 35 Exhibit II, # 36 Exhibit JJ, #
37 Exhibit KK)(Lowenthal, Mitchell) (Entered: 07/12/2010)
08/02/2010 46 MEMORANDUM OF LAW in Opposition re: 42 JOINT MOTION for Summary
Judgment /Notice of Joint Motion for Summary Judgment, dated July 12, 2010..
Document filed by Footbridge Limited Trust and OHP Opportunity Limited Trust.
(Burnett, David) (Entered: 08/02/2010)
08/02/2010 47 RESPONSE in Opposition re: 42 JOINT MOTION for Summary Judgment /Notice of
Joint Motion for Summary Judgment, dated July 12, 2010. Plaintiffs' Response to Rule
56.1 Statement. Document filed by Footbridge Limited Trust and OHP Opportunity
Limited Trust. (Burnett, David) (Entered: 08/02/2010)
08/02/2010 48 DECLARATION of Travis Pauley in Opposition re: 42 JOINT MOTION for
Summary Judgment /Notice of Joint Motion for Summary Judgment, dated July 12,
2010.. Document filed by Footbridge Limited Trust and OHP Opportunity Limited
Trust. (Burnett, David) (Entered: 08/02/2010)
08/02/2010 49 DECLARATION of Phil C. Appenzeller, Jr. in Opposition re: 42 JOINT MOTION for
Summary Judgment /Notice of Joint Motion for Summary Judgment, dated July 12,
2010.. Document filed by Footbridge Limited Trust and OHP Opportunity Limited
Trust. (Burnett, David) (Entered: 08/02/2010)
08/02/2010 50 DECLARATION of Sybil Lynn Wallace in Opposition re: 42 JOINT MOTION for
Summary Judgment /Notice of Joint Motion for Summary Judgment, dated July 12,
2010.. Document filed by Footbridge Limited Trust and OHP Opportunity Limited
Trust. (Burnett, David) (Entered: 08/02/2010)
08/02/2010 51 DECLARATION of David Burnett in Opposition re: 42 JOINT MOTION for
Summary Judgment /Notice of Joint Motion for Summary Judgment, dated July 12,
2010.. Document filed by Footbridge Limited Trust and OHP Opportunity Limited
Trust. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Exhibit, # 5 Exhibit, # 6
Exhibit, # 7 Exhibit, # 8 Exhibit, # 9 Exhibit, # 10 Exhibit, # 11 Exhibit, # 12 Exhibit,
# 13 Exhibit, # 14 Exhibit, # 15 Exhibit, # 16 Exhibit, # 17 Exhibit, # 18 Exhibit, # 19
Exhibit, # 20 Exhibit, # 21 Exhibit, # 22 Exhibit, # 23 Exhibit, # 24 Exhibit, # 25
Exhibit, # 26 Exhibit, # 27 Exhibit, # 28 Exhibit, # 29 Exhibit, # 30 Exhibit, # 31
Exhibit, # 32 Exhibit, # 33 Exhibit, # 34 Exhibit, # 35 Exhibit, # 36 Exhibit, # 37
Exhibit, # 38 Exhibit, # 39 Exhibit, # 40 Exhibit, # 41 Exhibit, # 42 Exhibit)(Burnett,
David) (Entered: 08/02/2010)
08/10/2010 52 NOTICE OF APPEARANCE by Marc Aaron Friedenberg on behalf of Footbridge
Limited Trust and OHP Opportunity Limited Trust (Friedenberg, Marc) (Entered:
08/10/2010)
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