日志

桑兰、海明两线交战

热度 8已有 15051 次阅读2013-4-10 02:40 |系统分类:法律| 案

桑兰对时代华纳一案中，原告桑兰方递交了第四版修正状纸，被告要求撤诉。而桑兰方反对撤诉。

当年海明大律师在时，双方打得硝烟弥漫，锣鼓喧天，结果海大律师败下阵来，还写了检讨书。
如今徐大律师力战群雄，双方开始比拼内力了。

就海明的检讨书而言，他递交动议要求撤销，副法官建议驳回其动议，但主审法官似乎还没有决断。海明还有一线生机。

不过海明大律师的麻烦不仅如此，桑兰在另一起案子中，控诉他诽谤、中伤等民事责任，海明因此成了被告。当年的兄妹如今对簿公堂，人生变幻啊。

这个案子也在进行之中。目前被告海明递交了撤诉动议，法官尚未作出裁决。

Date Filed	#	Docket Text
12/05/2011	82	OBJECTION to 81 Report and Recommendations by the Magistrate Judge Document filed by Sang Lan. (Attachments: # 1 Exhibit A, # 2 Exhibit C, # 3 Exhibit D, # 4 Affidavit of Service)(Hai, Ming) (Entered: 12/05/2011)
12/08/2011	83	OBJECTION to 81 Report and Recommendations by Defendants Document filed by K.S. Gina Hiu-Hung, Gina Liu, K.S. Liu, Hugh Mo, Winston Sie, Wilson Xue. (Attachments: # 1 Affidavit of Translation, # 2 Exhibit Photos of CD and Cover Pages, # 3 Exhibit English Translations)(Mo, Hugh) (Entered: 12/08/2011)
12/14/2011	84	MEMORANDUM: Having successfully moved to be relieved as an attorney after a motion to withdraw as attorney for plaintiff, Ming Hai has no standing to file any documents on behalf of plaintiff in this capacity. He seeks standing to file in the capacity of a party against whom defendants continue to seek monetary sanctions but his 23 page memorandum is not limited to the questions of this alleged liability. This document is not received on behalf of the plaintiff and will not be so regarded by this Court. If plaintiff wishes to file a document in response to the Magistrate's report she may do so by 1/31/2012 but not thereafter. Set Deadlines/Hearing as to (Objections to R&R due by 1/31/2012) (Signed by Judge Leonard B. Sand on 12/14/2011) (ft) (Entered: 12/15/2011)
12/15/2011	85	NOTICE OF APPEARANCE by X. Bing Xu on behalf of Sang Lan (Xu, X. Bing) (Entered: 12/15/2011)
12/15/2011	86	RULE 7.1 CORPORATE DISCLOSURE STATEMENT. No Corporate Parent. Document filed by Sang Lan.(Xu, X. Bing) (Entered: 12/15/2011)
01/23/2012	87	FILING ERROR - DEFICIENT DOCKET ENTRY - MOTION to Compel Ming Hai to turn over documents. Document filed by Sang Lan. Return Date set for 2/23/2012 at 09:00 AM. (Attachments: # 1 Affidavit Affirmation in support of Motion to Compel, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Supplement Case, # 8 Supplement Case2)(Xu, X. Bing) Modified on 1/24/2012 (ldi). (Entered: 01/23/2012)
01/23/2012		***NOTE TO ATTORNEY TO RE-FILE DOCUMENT - DEFICIENT DOCKET ENTRY ERROR. Note to Attorney X. Bing Xu to RE-FILE Document 87 MOTION to Compel Ming Hai to turn over documents. ERROR(S): Supporting documents must be filed separately, each receiving their own document number. Affirmation in Support of Motion is found under the event list Replies, Opposition and Supporting Documents. (ldi) (Entered: 01/24/2012)
01/24/2012	88	FILING ERROR - DEFICIENT DOCKET ENTRY - AFFIRMATION of Sang Lan in Support re: 87 MOTION to Compel Ming Hai to turn over documents. Document filed by Sang Lan. (Attachments: # 1 Exhibit Exhibit A, # 2 Exhibit Exhibit B)(Xu, X. Bing) Modified on 1/24/2012 (ldi). (Entered: 01/24/2012)
01/24/2012	89	FILING ERROR - DEFICIENT DOCKET ENTRY - AFFIRMATION of Sang Lan's former attorney Ming Hai in Opposition re: 87 MOTION to Compel Ming Hai to turn over documents.. Document filed by Sang Lan. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D)(Hai, Ming) Modified on 1/24/2012 (ldi). (Entered: 01/24/2012)
01/24/2012		***NOTE TO ATTORNEY TO RE-FILE DOCUMENT - DEFICIENT DOCKET ENTRY ERROR. Note to Attorney X. Bing Xu to RE-FILE Document 88 Affirmation in Support of Motion. ERROR(S): Document linked to filing error. (ldi) (Entered: 01/24/2012)
01/24/2012		***NOTE TO ATTORNEY TO RE-FILE DOCUMENT - DEFICIENT DOCKET ENTRY ERROR. Note to Attorney Ming Hai to RE-FILE Document 89 Affirmation in Opposition to Motion. ERROR(S): Document linked to filing error. (ldi) (Entered: 01/24/2012)
01/24/2012	90	MOTION to Compel Ming Hai to Turn Over Documents. Document filed by Sang Lan.(Xu, X. Bing) (Entered: 01/24/2012)
01/24/2012	91	AFFIRMATION of X. Bing Xu, Esquire in Support re: 90 MOTION to Compel Ming Hai to Turn Over Documents.. Document filed by Sang Lan. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E)(Xu, X. Bing) (Entered: 01/24/2012)
01/24/2012	92	AFFIRMATION of Sang Lan in Support re: 90 MOTION to Compel Ming Hai to Turn Over Documents.. Document filed by Sang Lan. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit B1, # 4 Exhibit B1 translation)(Xu, X. Bing) (Entered: 01/24/2012)
01/25/2012	93	AFFIRMATION of Sang Lan's former attorney Ming Hai in Opposition re: 90 MOTION to Compel Ming Hai to Turn Over Documents.. Document filed by Sang Lan. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D)(Hai, Ming) (Entered: 01/25/2012)
01/26/2012	94	RESPONSE re: 81 Report and Recommendations,,,,, 84 Order, Set Motion and R&R Deadlines/Hearings,,,,,,. Document filed by Sang Lan. (Xu, X. Bing) (Entered: 01/26/2012)
02/03/2012	95	ORDER: Settlement Conference set for 2/27/2012 at 09:00 AM in Courtroom 18D, 500 Pearl Street, New York, NY 10007 before Magistrate Judge James C. Francis, and as further set forth in this document. (Signed by Magistrate Judge James C. Francis on 2/3/2012) Copies Mailed By Chambers. (cd) (Entered: 02/03/2012)
02/27/2012		Minute Entry for proceedings held before Magistrate Judge James C. Francis: Settlement Conference held on 2/27/2012. (js) (Entered: 02/29/2012)
03/02/2012	96	STIPULATION AND ORDER OF PARTIAL DISMISSAL OF RULE 11 MOTION: the undersigned counsel hereby consents to the partial dismissal of their pending Motion for Sanctions. pursuant to Fed. R. Civ. P. Rule 11, only as against attorney Ming Hai, Esq., with prejudice, and without costs, expenses or attorneys' fees to any of the parties as against the other, and pursuant to the attached Agreement of Settlement, with the settlement amount redacted. (Signed by Magistrate Judge James C. Francis on 3/2/2012) (pl) Modified on 3/5/2012 (pl). (Main Document 96 replaced on 3/6/2012, See Page 3 replaced. See Endorsed Letter 97 which ordered that this page be replaced.) (tro). Modified on 3/6/2012 (tro). (Main Document 96 replaced on 3/7/2012, pursuant to instructions from Chambers, page 3 redacted) (tro). Modified on 3/7/2012 (tro). (Entered: 03/05/2012)
03/06/2012	97	ENDORSED LETTER addressed to Magistrate Judge James C. Francis IV from Hugh H. Mo dated 3/4/2012 re: We kindly ask the Court to replace the first page of the Settlement Agreement with the enclosed copy, which includes a footnote. ENDORSEMENT: Application granted. The Settlement Agreement and release is amended accordingly. So ordered. (Signed by Magistrate Judge James C. Francis on 3/6/2012) (rjm) (Main Document 97 replaced on 3/7/2012, as per Chamber's instructions, page 2 redacted version) (tro). Modified on 3/7/2012 (tro). (Entered: 03/06/2012)
04/23/2012		***NOTE TO ATTORNEY TO E-MAIL PDF. Note to Attorney X. Bing Xu for noncompliance with Section 14.3 of the S.D.N.Y. Electronic Case Filing Rules & Instructions. E-MAIL the PDF for Document 1 Complaint, to: caseopenings@nysd.uscourts.gov. (rjm) (Entered: 04/23/2012)
04/23/2012		***NOTE TO ATTORNEY TO E-MAIL PDF. Note to Attorney X. Bing Xu for noncompliance with Section 14.3 of the S.D.N.Y. Electronic Case Filing Rules & Instructions. E-MAIL the PDF for Document 4 Amended Complaint, to: caseopenings@nysd.uscourts.gov. (rjm) (Entered: 04/23/2012)
04/23/2012		***NOTE TO ATTORNEY TO E-MAIL PDF. Note to Attorney X. Bing Xu to E-MAIL the PDF for Document 32 Amended Complaint to: caseopenings@nysd.uscourts.gov. All pdfs must include case number and corresponding document number. (rjm) (Entered: 04/23/2012)
05/09/2012	98	MEMORANDUM AND ORDER: for 47 Motion for Sanctions filed by Winston Sie, K.S. Gina Hiu-Hung, K.S. Liu, Gina Liu, Wilson Xue, Hugh Mo, 81 Report and Recommendations, 34 Motion to Dismiss/Lack of Jurisdiction filed by Winston Sie, K.S. Gina Hiu-Hung, K.S. Liu, Gina Liu, Wilson Xue, Hugh Mo, 28 Motion to Dismiss Case as Frivolous filed by K.S. Gina Hiu-Hung, K.S. Liu, Wilson Xue, Hugh Mo, 43 Motion to Amend/Correct filed by Sang Lan. For the above reasons, Defendants' motion for sanctions against Plaintiff is denied: Defendants' motion to dismiss Count 9 is granted with leave to replead; and Defendants' motion to dismiss Count 10 is granted with respect to Hugh Mo and denied with respect to K.S. Liu and Gina Liu. In all other respects, Judge Francis's R&R is affirmed. (Signed by Judge Leonard B. Sand on 5/9/2012) (jfe) (Entered: 05/09/2012)
05/10/2012	99	FILING ERROR - ELECTRONIC FILING FOR NON-ECF DOCUMENT - FIRST MOTION to Set Aside 96 Stipulation and Order of Dismissal,,, by Ming Hai, former attorney for Plainitff. Document filed by Sang Lan. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Errata C, # 4 Exhibit D, # 5 Affidavit of Service)(Hai, Ming) Modified on 5/11/2012 (ldi). (Entered: 05/10/2012)
05/10/2012		***NOTE TO ATTORNEY THAT THE ATTEMPTED FILING OF Document No. 99 HAS BEEN REJECTED. Note to Attorney Ming Hai : THE CLERK'S OFFICE DOES NOT ACCEPT LETTERS FOR FILING, either through ECF or otherwise, except where the judge has ordered that a particular letter be docketed. Letters may be sent directly to a judge. (ldi) (Entered: 05/11/2012)
05/11/2012	100	FILING ERROR - DEFICIENT DOCKET ENTRY - FIRST MOTION to Set Aside 96 Stipulation and Order of Dismissal,,, by Ming Hai, former attorney for plaintiff. Document filed by Sang Lan.(Hai, Ming) Modified on 5/14/2012 (db). (Entered: 05/11/2012)
05/11/2012	101	FILING ERROR - DEFICIENT DOCKET ENTRY - AFFIRMATION of Ming Hai in Support re: 100 FIRST MOTION to Set Aside 96 Stipulation and Order of Dismissal,,, by Ming Hai, former attorney for plaintiff.. Document filed by Sang Lan. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Affidavit of Service)(Hai, Ming) Modified on 5/14/2012 (db). (Entered: 05/11/2012)
05/14/2012		**NOTE TO ATTORNEY TO RE-FILE DOCUMENT - DEFICIENT DOCKET ENTRY ERROR. Note to Attorney Ming Hai to RE-FILE Document 100 FIRST MOTION to Set Aside 96 Stipulation and Order of Dismissal, by Ming Hai, former attorney for plaintiff. FIRST MOTION to Set Aside 96 Stipulation and Order of Dismissal, by Ming Hai, former attorney for plaintiff*. ERROR(S): No signature or s/. (db) (Entered: 05/14/2012)
05/14/2012		***NOTE TO ATTORNEY TO RE-FILE DOCUMENT - DEFICIENT DOCKET ENTRY ERROR. Note to Attorney Ming Hai to RE-FILE Document 101 Affirmation in Support of Motion. ERROR(S): Document linked to filing error. (db) (Entered: 05/14/2012)
05/14/2012	102	ORDER REFERRING CASE TO MAGISTRATE JUDGE. Order that case be referred to the Clerk of Court for assignment to a Magistrate Judge for Specific Non-Dispositive Motion/Dispute: Ming Hai's 5/10/2012 Motion to Set Aside Stipulation and Order of Dismissal. Referred to Magistrate Judge James C. Francis. (Signed by Judge Leonard B. Sand on 5/14/2012) (cd) (Entered: 05/14/2012)
05/14/2012	103	MOTION to Set Aside 96 Stipulation and Order of Dismissal,,,. Document filed by Ming Hai.(Hai, Ming) (Entered: 05/14/2012)
05/14/2012	104	AFFIRMATION of Ming Hai in Support re: 103 MOTION to Set Aside 96 Stipulation and Order of Dismissal,,,.. Document filed by Ming Hai. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Affidavit of Service)(Hai, Ming) (Entered: 05/14/2012)
05/14/2012		Transmission to Case Assignment Clerk. Transmitted re: 102 Order Referring Case to Magistrate Judge, to the Case Assignment Clerk for preparation of notice of case assignment/reassignment. (cd) (Entered: 05/29/2012)
05/29/2012	105	NOTICE OF REASSIGNMENT OF A REFERRAL TO ANOTHER MAGISTRATE JUDGE. The referral in the above entitled action has been reassigned to Magistrate Judge James C. Francis, for Specific Non-Dispositive Motion/Dispute. Magistrate Judge James C. Francis no longer referred to the case. (sjo) (Entered: 05/29/2012)
06/05/2012	107	ORDER: Set Deadlines/Hearing as to 103 MOTION to Set Aside 96 Stipulation and Order of Dismissal:( Responses due by 6/29/2012, Replies due by 7/13/2012.) (Signed by Magistrate Judge James C. Francis on 6/5/2012) Copies Mailed By Chambers. (cd) (Entered: 06/05/2012)
06/05/2012		Minute Entry for proceedings held before Magistrate Judge James C. Francis: Telephone Conference held on 6/5/2012. (cd) (Entered: 06/06/2012)
06/29/2012	108	MEMORANDUM OF LAW in Opposition re: 103 MOTION to Set Aside 96 Stipulation and Order of Dismissal,,,.. Document filed by K.S. Gina Hiu-Hung, Gina Liu, K.S. Liu, Hugh Mo. (Mo, Hugh) (Entered: 06/29/2012)
06/29/2012	109	DECLARATION of Hugh H. Mo in Opposition re: 103 MOTION to Set Aside 96 Stipulation and Order of Dismissal,,,.. Document filed by K.S. Gina Hiu-Hung, Gina Liu, K.S. Liu, Hugh Mo. (Attachments: # 1 Exhibit "A", # 2 Exhibit "B", # 3 Exhibit "C", # 4 Exhibit "D", # 5 Exhibit "E", # 6 Exhibit "F")(Mo, Hugh) (Entered: 06/29/2012)
07/03/2012	110	CERTIFICATE OF SERVICE of Memorandum of Law in Opposition to Attorney Hai's Motion to Set Aside Settlement, Declaration of Hugh H. Mo, Esq., and exhibits served on SANG LAN and MING HAI, ESQ. on 06/29/12. Service was made by MAIL. Document filed by K.S. Gina Hiu-Hung, Gina Liu, K.S. Liu, Hugh Mo. (Mo, Hugh) (Entered: 07/03/2012)
07/12/2012	111	REPLY AFFIRMATION of Ming Hai in Support re: 103 MOTION to Set Aside 96 Stipulation and Order of Dismissal,,,.. Document filed by Ming Hai. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Affidavit of Service)(Hai, Ming) (Entered: 07/12/2012)
07/25/2012	112	ORDER: A pretrial conference having been held by telephone on July 25, 2012, it is hereby ORDERED as follows: 1. Any motion to amend the pleadings shall be served and filed by October 7, 2012. 2. All discovery shall be completed by February 28, 2013. 3. The pretrial order shall be submitted by March 29, 2013 unless any dispositive motion is filed by that date. If such a motion is filed, the pretrial order shall be due thirty days after the motion is decided. ( Discovery due by 2/28/2013. Motions due by 10/7/2012. Pretrial Order due by 3/29/2013.) (Signed by Magistrate Judge James C. Francis on 7/25/2012) Copies Mailed By Chambers. (ja) (Entered: 07/25/2012)
08/13/2012	113	REPORT AND RECOMMENDATION: re: 103 MOTION to Set Aside 96 Stipulation and Order of Dismissal, filed by Ming Hai. For the reasons set forth above, Mr. Hais motion to rescind the settlement agreement (Docket no. 103) should be denied. Objections to R&R due by 8/30/2012 (Signed by Magistrate Judge James C. Francis on 8/13/2012) Copies Mailed By Chambers. (jfe) (Entered: 08/14/2012)
08/27/2012	114	OBJECTION to 113 Report and Recommendations Document filed by Ming Hai. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Affidavit of Service)(Hai, Ming) (Entered: 08/27/2012)
10/05/2012	115	MOTION to Add Party(ies) Time Warner, Inc.. Document filed by Sang Lan.(Xu, X. Bing) (Entered: 10/05/2012)
10/05/2012	116	AFFIRMATION of X. Bing Xu, Esquire in Support re: 115 MOTION to Add Party(ies) Time Warner, Inc... Document filed by Sang Lan. (Attachments: # 1 Supplement 4th Amended Complaint, # 2 Exhibit exhibit a-f to cpl, # 3 Exhibit exhibit g-j to cpl, # 4 Exhibit exhibit k-m to cpl)(Xu, X. Bing) (Entered: 10/05/2012)
11/05/2012	118	JOINT STIPULATION AND ORDER ON BRIEFING SCHEDULE: Time Warner, the Liu's, and Attorney Mo wish to proceed directly to motions challenging the allegations in the Fourth Amended Complaint. Time Warner, the Liu's, and Attorney Mo take no position Plaintiff's Motion to Add Party. Accordingly, Plaintiffs Motion to Add Party (Docket No. 115) is granted and the Fourth Amended Complaint shall be deemed filed as of the date of this Stipulation. This Stipulation may be executed in two or more counterparts, each of which shall be deemed an original including facsimile, copy or email forms, and all of which together shall constitute one and the same document. SO ORDERED. John Does and Jane Does #1 through 15, Inclusive answer due 12/14/2012; Gina Liu answer due 12/14/2012; K.S. Liu answer due 12/14/2012; Hugh Mo answer due 12/14/2012; Ted Turner answer due 12/14/2012.( Responses due by 1/30/2013, Replies due by 2/27/2013.) (Signed by Magistrate Judge James C. Francis on 11/05/2012) (ama) (Entered: 11/05/2012)
11/20/2012	119	FOURTH AMENDED COMPLAINT amending 32 Amended Complaint, against Time Warner, Inc., Keo-Sung Liu, Gina Hiu-Hung Liu, Gina Hiu-Hung Liu, Hugh Hu Mo, Does 1-30 with JURY DEMAND.Document filed by Sang Lan. Related document: 32 Amended Complaint, filed by Sang Lan.(mro) (Additional attachment(s) added on 12/17/2012: # 1 Exhibit A to F, # 2 Exhibit g j, # 3 Exhibit k m) (sac). (Entered: 11/21/2012)
12/03/2012		***NOTE TO ATTORNEY TO E-MAIL PDF. Note to Attorney X. Bing Xu for noncompliance with Section 14.3 of the S.D.N.Y. Electronic Case Filing Rules & Instructions. E-MAIL the PDF for Document 119 Amended Complaint, to: caseopenings@nysd.uscourts.gov. (mro) (Entered: 12/03/2012)
12/06/2012	120	MOTION for Alan W. Bakowski to Appear Pro Hac Vice. Filing fee $ 200.00, receipt number 0208-8038498. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Time Warner, Inc.. (Attachments: # 1 Exhibit Certificates of Good Standing, # 2 Text of Proposed Order)(Bakowski, Alan) (Entered: 12/06/2012)
12/06/2012	121	MOTION for James A. Lamberth to Appear Pro Hac Vice. Filing fee $ 200.00, receipt number 0208-8038667. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Time Warner, Inc.. (Attachments: # 1 Exhibit Certificates of Good Standing, # 2 Text of Proposed Order)(Lamberth, James) (Entered: 12/06/2012)
12/06/2012		>>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. 120 MOTION for Alan W. Bakowski to Appear Pro Hac Vice. Filing fee $ 200.00, receipt number 0208-8038498. Motion and supporting papers to be reviewed by Clerk's Office staff., 121 MOTION for James A. Lamberth to Appear Pro Hac Vice. Filing fee $ 200.00, receipt number 0208-8038667. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (bcu) (Entered: 12/06/2012)
12/10/2012	122	ORDER FOR ADMISSION PRO HAC VICE: granting 121 Motion for James A. Lamberth to Appear Pro Hac Vice. (Signed by Magistrate Judge James C. Francis on 12/10/2012) (djc) (Entered: 12/11/2012)
12/10/2012	123	ORDER FOR ADMISSION PRO HAC VICE: granting 120 Motion for Alan W. Bakowski to Appear Pro Hac Vice. (Signed by Magistrate Judge James C. Francis on 12/10/2012) (djc) (Entered: 12/11/2012)
12/12/2012	124	ENDORSED LETTER addressed to Magistrate Judge James C. Francis from Hugh H. Mo dated 12/12/2012 re: Defense counsel writes due to unforeseen circumstances and delays, including repercussions from Hurricane Sandy, the Individual Defendants respectfully ask Your Honor to grant, this application for a brief two-week extension of time to answer, move or otherwise respond to Plaintiff's Fourth Amended Complaint to December 28, 2012. This constitutes our first application as it pertains to the Fourth Amended Complaint. ENDORSEMENT: Application granted. So Ordered., K.S. Gina Hiu-Hung answer due 12/28/2012; Gina Hiu-Hung Liu(individually) answer due 12/28/2012; Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund) answer due 12/28/2012; Hugh Hu Mo answer due 12/28/2012. (Signed by Magistrate Judge James C. Francis on 12/12/2012) (ago) (Entered: 12/12/2012)
12/14/2012	125	WAIVER OF SERVICE RETURNED EXECUTED. All Plaintiffs. Document filed by Time Warner, Inc.. (Xu, X. Bing) (Entered: 12/14/2012)
12/14/2012	126	RULE 7.1 CORPORATE DISCLOSURE STATEMENT. No Corporate Parent. Document filed by Time Warner, Inc..(Bakowski, Alan) (Entered: 12/14/2012)
12/14/2012	127	MOTION to Dismiss Plaintiff's Fourth Amended Complaint for Failure to State a Claim Upon Which Relief Can Be Granted. Document filed by Time Warner, Inc.. Responses due by 1/30/2013(Bakowski, Alan) (Entered: 12/14/2012)
12/14/2012	128	MEMORANDUM OF LAW in Support re: 127 MOTION to Dismiss Plaintiff's Fourth Amended Complaint for Failure to State a Claim Upon Which Relief Can Be Granted.. Document filed by Time Warner, Inc.. (Bakowski, Alan) (Entered: 12/14/2012)
12/14/2012	129	DECLARATION of Alan W. Bakowski in Support re: 127 MOTION to Dismiss Plaintiff's Fourth Amended Complaint for Failure to State a Claim Upon Which Relief Can Be Granted.. Document filed by Time Warner, Inc.. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4)(Bakowski, Alan) (Entered: 12/14/2012)
12/27/2012	130	MOTION to Dismiss FOURTH AMENDED COMPLAINT. Document filed by K.S. Gina Hiu-Hung, Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Gina Liu, K.S. Liu, Hugh Mo. Responses due by 1/30/2013 (Attachments: # 1 Exhibit Letter Requesting Oral Argument)(Mo, Hugh) (Entered: 12/27/2012)
12/27/2012	131	MEMORANDUM OF LAW in Support re: 130 MOTION to Dismiss FOURTH AMENDED COMPLAINT.. Document filed by K.S. Gina Hiu-Hung, Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Gina Liu, K.S. Liu, Hugh Mo. (Mo, Hugh) (Entered: 12/27/2012)
12/27/2012	132	DECLARATION of Hugh H. Mo, Esq. in Support re: 130 MOTION to Dismiss FOURTH AMENDED COMPLAINT.. Document filed by K.S. Gina Hiu-Hung, Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Gina Liu, K.S. Liu, Hugh Mo. (Attachments: # 1 Exhibit Exhibit "A")(Mo, Hugh) (Entered: 12/27/2012)
12/27/2012	133	CERTIFICATE OF SERVICE of NOTICE OF MOTION TO DISMISS FOURTH AMENDED COMPLAINT, MEMORANDUM OF LAW IN SUPPORT, DECLARATION IN SUPPORT, AND EXHIBITS served on ALL PARTIES on 12/27/2012. Service was made by MAIL. Document filed by K.S. Gina Hiu-Hung, Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Gina Liu, K.S. Liu, Hugh Mo. (Mo, Hugh) (Entered: 12/27/2012)
01/29/2013	134	ENDORSED LETTER addressed to Magistrate Judge James C. Francis, IV, from X. Bing Xu, dated 1/29/2013, re: request for additional time to file Plaintiff's response to defendants' Motion to Dismiss. ENDORSEMENT: Plaintiff is hereby granted extension of time to respond to Defendant Lius and Mo's Motion to Dismiss on or before February 15, 2013; Defendant Lius and Mo shall file their reply on or before March 1, 2013. Plaintiff is hereby granted extension of time to respond to Defendant Time Warner's Motion to Dismiss on or before February 15 2013; Defendant Time Warner shall file its reply on or before March 1, 2013. So Ordered. ( Motions due by 2/15/2013, Responses due by 2/15/2013, Replies due by 3/1/2013.) (Signed by Magistrate Judge James C. Francis on 1/29/2013) (ja) (Entered: 01/29/2013)
02/15/2013	135	MEMORANDUM OF LAW in Opposition re: 127 MOTION to Dismiss Plaintiff's Fourth Amended Complaint for Failure to State a Claim Upon Which Relief Can Be Granted.. Document filed by Sang Lan. (Xu, X. Bing) (Entered: 02/15/2013)
02/15/2013	136	MEMORANDUM OF LAW in Opposition re: 130 MOTION to Dismiss FOURTH AMENDED COMPLAINT.. Document filed by Sang Lan. (Xu, X. Bing) (Entered: 02/15/2013)
03/01/2013	137	REPLY MEMORANDUM OF LAW in Support re: 130 MOTION to Dismiss FOURTH AMENDED COMPLAINT.. Document filed by K.S. Gina Hiu-Hung, Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Gina Liu, K.S. Liu, Hugh Mo. (Mo, Hugh) (Entered: 03/01/2013)
03/01/2013	138	CERTIFICATE OF SERVICE of Defendants' Reply Memorandum of Law served on Sang Lan and Time Warner, Inc. on 03/01/13. Service was made by MAIL. Document filed by K.S. Gina Hiu-Hung, Gina Hiu-Hung Liu(individually), Gina Hiu-Hung Liu(as trustees or managers of Goodwill For Sang Lan Fund), Hugh Hu Mo, Gina Liu, K.S. Liu, Keo-Sung Liu, Hugh Mo. (Mo, Hugh) (Entered: 03/01/2013)
03/01/2013	139	REPLY MEMORANDUM OF LAW in Support re: 127 MOTION to Dismiss Plaintiff's Fourth Amended Complaint for Failure to State a Claim Upon Which Relief Can Be Granted.. Document filed by Time Warner, Inc.. (Bakowski, Alan) (Entered: 03/01/2013)

Sang v. Hai et al
Assigned to: Judge J. Paul Oetken
Cause: 28:1332 Diversity-Libel,Assault,Slander

Date Filed: 09/20/2012
Jury Demand: Plaintiff
Nature of Suit: 320 Assault Libel & Slander
Jurisdiction: Diversity

Plaintiff
Lan Sang	represented by	Allan Steven Schiller Schiller Law Group PC 130 West 42nd Street New York, NY 10036 718)-268-9800 Fax: 718)-268-9892 Email: as@asfirm.com ATTORNEY TO BE NOTICED

V.
Defendant
Ming Hai	represented by	Dianna L. Daghir McCarthy Winget, Spadafora & Schwartzberg, LLP 45 Broadway, 19th Floor New York, NY 10006 (212) 221-6900 Fax: (212)-221-6989 Email: mccarthy.d@wssllp.com LEAD ATTORNEY ATTORNEY TO BE NOTICED Tania Jaynelle Mistretta Winget, Spadafora & Schwartzberg, LLP 45 Broadway New York, NY 10006 (212) 221-6900 Fax: (212) 221-6989 Email: mistretta.t@wssllp.com LEAD ATTORNEY ATTORNEY TO BE NOTICED

Defendant
Law Office of Ming Hai, P.C.	represented by	Dianna L. Daghir McCarthy (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED Tania Jaynelle Mistretta (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Date Filed	#	Docket Text
09/20/2012	1	COMPLAINT against Ming Hai, Law Office of Ming Hai, P.C. (Filing Fee $ 350.00, Receipt Number 1049179)Document filed by Lan Sang.(mro) (mro). (Entered: 09/21/2012)
09/20/2012		SUMMONS ISSUED as to Ming Hai, Law Office of Ming Hai, P.C. (mro) (Entered: 09/21/2012)
09/20/2012		Magistrate Judge Debra C. Freeman is so designated. (mro) (Entered: 09/21/2012)
09/20/2012		Case Designated ECF. (mro) (Entered: 09/21/2012)
09/24/2012	2	SUMMONS RETURNED EXECUTED Summons and Complaint served. All Defendants. Service was accepted by Ming Hai. Document filed by Lan Sang. (Schiller, Allan) (Entered: 09/24/2012)
10/01/2012	3	NOTICE OF APPEARANCE by Dianna L. Daghir McCarthy on behalf of Ming Hai, Law Office of Ming Hai, P.C. (McCarthy, Dianna) (Entered: 10/01/2012)
10/01/2012	4	NOTICE OF APPEARANCE by Tania Jaynelle Mistretta on behalf of Ming Hai, Law Office of Ming Hai, P.C. (Mistretta, Tania) (Entered: 10/01/2012)
10/02/2012	5	NOTICE OF CHANGE OF ADDRESS by Allan Steven Schiller on behalf of Lan Sang. New Address: SCHILLER LAW GROUP PC, 130 WEST 42 STREET, NEW YORK, NEW YORK, USA 10036, 212-768-8700. (Schiller, Allan) (Entered: 10/02/2012)
10/05/2012	6	ENDORSED LETTER addressed to Judge J. Paul Oetken from Tania Mistretta dated 10/4/2012 re: We request an extension to respond or otherwise move through and including October 31, 2012. ENDORSEMENT: Application granted., Ming Hai answer due 10/31/2012; Law Office of Ming Hai, P.C. answer due 10/31/2012. (Signed by Judge J. Paul Oetken on 10/5/2012) (lmb) (Entered: 10/05/2012)
10/10/2012	7	FIRST AMENDED COMPLAINT amending 1 Complaint against Ming Hai, Law Office of Ming Hai, P.C. with JURY DEMAND.Document filed by Lan Sang. Related document: 1 Complaint filed by Lan Sang.(cd) (Entered: 10/15/2012)
10/22/2012	8	ENDORSED LETTER addressed to Judge J. Paul Oetken from Tania Mistretta, Esq. dated 10/17/2012 re: Tn light of Plaintiff's recent amendment to the complaint, we write to request an extension of time to respond or otherwise move on behalf of Defendants. We now request an extension of time for Defendants to respond to the Amended Complaint, or otherwise move, through and including November 21, 2012. ENDORSEMENT: APPLICATION GRANTED. (Signed by Judge J. Paul Oetken on 10/20/2012) (mt) (Entered: 10/22/2012)
10/22/2012		Set/Reset Deadlines: Ming Hai answer due 11/21/2012; Law Office of Ming Hai, P.C. answer due 11/21/2012. (mt) (Entered: 10/22/2012)
10/22/2012		***DELETED DOCUMENT. Deleted document number 9 ORDER ADMITTING ATTORNEY PRO HAC VICE. The document was incorrectly filed in this case. (mt) (Entered: 10/22/2012)
11/21/2012	9	FILING ERROR - DEFICIENT DOCKET ENTRY - MOTION to Dismiss. Document filed by Ming Hai, Law Office of Ming Hai, P.C.. (Attachments: # 1 Declaration of Dianna D. McCarthy in Support, # 2 Exhibits A-E to McCarthy Decl., # 3 Memorandum of Law in Support of Motion to Dismiss, # 4 Appendices A-F to Memorandum of Law in Support of Motion to Dismiss)(McCarthy, Dianna) Modified on 11/26/2012 (ldi). (Entered: 11/21/2012)
11/21/2012		***NOTE TO ATTORNEY TO RE-FILE DOCUMENT - DEFICIENT DOCKET ENTRY ERROR. Note to Attorney Dianna L. Daghir McCarthy to RE-FILE Document 9 MOTION to Dismiss. ERROR(S): Supporting documents must be filed separately, each receiving their own document number. Declaration in Support of Motion and Memorandum of Law in Support of Motion are both found under the event list Replies, Opposition and Supporting Documents. (ldi) (Entered: 11/26/2012)
11/26/2012	10	MOTION to Dismiss Amended Complaint. Document filed by Ming Hai, Law Office of Ming Hai, P.C..(McCarthy, Dianna) (Entered: 11/26/2012)
11/26/2012	11	DECLARATION of Dianna D. McCarthy in Support re: 10 MOTION to Dismiss Amended Complaint.. Document filed by Ming Hai, Law Office of Ming Hai, P.C.. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E)(McCarthy, Dianna) (Entered: 11/26/2012)
11/26/2012	12	MEMORANDUM OF LAW in Support re: 10 MOTION to Dismiss Amended Complaint.. Document filed by Ming Hai, Law Office of Ming Hai, P.C.. (Attachments: # 1 Appendix A, # 2 Appendix B, # 3 Appendix C, # 4 Appendix D, # 5 Appendix E, # 6 Appendix F)(McCarthy, Dianna) (Entered: 11/26/2012)
11/26/2012	13	CERTIFICATE OF SERVICE of Notice of Motion to Dismiss, Declaration in Support, and Memorandum of Law in Support served on Allan Schiller on November 21, 2012. Service was made by Mail. Document filed by Ming Hai, Law Office of Ming Hai, P.C.. (Mistretta, Tania) (Entered: 11/26/2012)
12/04/2012	14	Letter addressed to Judge J. Paul Oetken from Allan Schiller dated 12/3/2012 re: This letter is to inform the Court and opposing counsel pursuant to the individual practices of the Court, that the Plaintiff elects to amend the pleading challenged by defendants' pending motion to dismiss. The Plaintiff will file an amended complaint on or before December 18, 2012. The undersigned has conferred with opposing counsel who has informed the undersigned that Defendants take no position to the amendment and that December 18, 2012 is an acceptable date. Document filed by Lan Sang.(djc) (Entered: 12/04/2012)
12/04/2012		Set Deadlines/Hearings: Amended Pleadings due by 12/18/2012. (djc) (Entered: 12/04/2012)
12/18/2012	15	FIRST MOTION to Amend/Correct Complaint. Document filed by Lan Sang.(Schiller, Allan) (Entered: 12/18/2012)
12/18/2012	16	DECLARATION of Allan Schiller in Support re: 10 MOTION to Dismiss Amended Complaint., 15 FIRST MOTION to Amend/Correct Complaint.. Document filed by Lan Sang. (Attachments: # 1 Exhibit A)(Schiller, Allan) (Entered: 12/18/2012)
12/18/2012	17	CERTIFICATE OF SERVICE of Notice of Motion, Declaration, Exhibit A Second Amended Complaint served on Winget, Spadafora & Schwartzberg LLP on 12/18/2012. Document filed by Lan Sang. (Schiller, Allan) (Entered: 12/18/2012)
01/14/2013	18	ORDER denying as moot 10 Motion to Dismiss; granting 15 Motion to Amend/Correct. Plaintiff's Motion to Amend (Dkt. No. 15) is GRANTED. Defendant's Motion to Dismiss (Dkt. No. 10) is therefore DENIED as moot. Defendant has until January 28, 2013 to answer or move to dismiss Plaintiff's Amended Complaint. In the event that Defendant moves to dismiss, Plaintiff has until February 18, 2013 to oppose Defendant's motion; Defendant then has until March 4, 2013 to reply. The Clerk of the Court is directed to close the motions at Docket Nos. 10 and 15. (Signed by Judge J. Paul Oetken on 1/11/2013) (ft) (Entered: 01/14/2013)
01/14/2013		Set/Reset Deadlines: Ming Hai answer due 1/28/2013; Law Office of Ming Hai, P.C. answer due 1/28/2013. Responses due by 2/18/2013. Replies due by 3/4/2013. (ft) (Entered: 01/14/2013)
01/25/2013	19	ENDORSED LETTER addressed to Judge J. Paul Oetken from Tania Mistretta dated 1/24/13 re: Counsel writes to request a ten page limit extension of the Court's twenty-five page limit for memoranda of law. ENDORSEMENT: Application granted. (Signed by Judge J. Paul Oetken on 1/24/2013) (mro) (Entered: 01/25/2013)
01/28/2013	20	MOTION to Dismiss Plaintiff's Second Amended Complaint. Document filed by Ming Hai, Law Office of Ming Hai, P.C.. Responses due by 2/18/2013(McCarthy, Dianna) (Entered: 01/28/2013)
01/28/2013	21	DECLARATION of Dianna D. McCarthy in Support re: 20 MOTION to Dismiss Plaintiff's Second Amended Complaint.. Document filed by Ming Hai, Law Office of Ming Hai, P.C.. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E)(McCarthy, Dianna) (Entered: 01/28/2013)
01/28/2013	22	MEMORANDUM OF LAW in Support re: 20 MOTION to Dismiss Plaintiff's Second Amended Complaint.. Document filed by Ming Hai, Law Office of Ming Hai, P.C.. (McCarthy, Dianna) (Entered: 01/28/2013)
01/28/2013	23	CERTIFICATE OF SERVICE of Motion to Dismiss served on Allan Schiller on January 28, 2013. Service was made by Mail. Document filed by Ming Hai, Law Office of Ming Hai, P.C.. (Mistretta, Tania) (Entered: 01/28/2013)
02/18/2013	24	MEMORANDUM OF LAW in Opposition re: 20 MOTION to Dismiss Plaintiff's Second Amended Complaint.. Document filed by Lan Sang. (Schiller, Allan) (Entered: 02/18/2013)
02/18/2013	25	DECLARATION of John V. Golaszewski, Esq. in Opposition re: 20 MOTION to Dismiss Plaintiff's Second Amended Complaint.. Document filed by Lan Sang. (Schiller, Allan) (Entered: 02/18/2013)
02/20/2013	26	CERTIFICATE OF SERVICE of Opposition to Motion to Dismiss and Declaration of John V. Golaszewski served on Dianna D. McCarthy on February 18, 2013. Service was made by Mail. Document filed by Lan Sang. (Schiller, Allan) (Entered: 02/20/2013)
03/04/2013	27	REPLY MEMORANDUM OF LAW in Support re: 20 MOTION to Dismiss Plaintiff's Second Amended Complaint.. Document filed by Ming Hai, Law Office of Ming Hai, P.C.. (McCarthy, Dianna) (Entered: 03/04/2013)
03/04/2013	28	CERTIFICATE OF SERVICE of Reply Brief in Further Support served on Allan Schiller on March 4, 2013. Service was made by Mail. Document filed by Ming Hai, Law Office of Ming Hai, P.C.. (Mistretta, Tania) (Entered: 03/04/2013)
03/06/2013	29	ENDORSED LETTER addressed to Judge J. Paul Oetken from Tania Mistretta dated 3/1/2013 re: Counsel requests a 5 page extension of the Court's 10 page limit for reply memoranda of law. ENDORSEMENT: APPLICATION GRANTED. (Signed by Judge J. Paul Oetken on 3/5/2013) (tro) (Entered: 03/06/2013)
03/12/2013		Please be advised that Judge Oetken's Courtroom and Chambers have been moved to the Thurgood Marshall United States Courthouse located at 40 Foley Square, New York, New York 10007. Effective immediately, all proceedings before the Court will take place in Courtroom 706. Judge Oetken's Chambers are located in Room 2101, 40 Foley Square. The Court's Individual Practices remain available at http://www.nysd.uscourts.gov/judge/Oetken. (Skolnik, Brandon) (Entered: 03/12/2013)