From Casetext: Smarter Legal Research

Papadopoulous v. Mylonas

United States District Court, E.D. Pennsylvania
Oct 31, 2011
CIVIL ACTION NO. 11-4163 (E.D. Pa. Oct. 31, 2011)

Opinion

CIVIL ACTION NO. 11-4163.

October 31, 2011


OPINION


I. INTRODUCTION

By Order of October 13, 2011, counsel for Plaintiff and Defendants were directed to file memoranda of law on the issue of whether this Court had jurisdiction to decide the Motion for Reconsideration. (Doc. No. 23.) Before the Court are the memoranda of law from counsel for all parties. (Doc. Nos. 24 25.) For reasons that follow, the Court will vacate the October 11, 2011 Order granting Defendants' Motion to Reconsider (Doc. No. 22), which will allow this case to remain in state court where it has been since a certified copy of the September 6, 2011 Order granting remand was mailed to state court by the Clerk of Court (Doc. No. 18).

II. BACKGROUND

The factual information in the "Background" section of this Opinion, save for several updates, is also contained in the Opinion dated October 11, 2011 granting the Motion for Reconsideration.

This case involves a claim of legal malpractice. On May 19, 2011, Plaintiff Anastasios Papadopoulous filed his original Complaint in the Court of Common Pleas of Philadelphia County against Defendants Peter G. Mylonas, Esquire, and Peter G. Mylonas, P.C. On June 27, 2011, Defendants removed the case to this Court based on diversity of citizenship jurisdiction pursuant to 28 U.S.C. § 1332. (Doc. No. 1.) Thereafter, Plaintiff filed an untimely Motion to Remand and requested that the Court not deny the Motion for being filed untimely but to consider it on the merits. (Doc. No. 11.) Plaintiff also filed a Second Motion to Remand requesting that the Court rule on the outstanding Motion for Remand prior to determining the citizenship of Plaintiff. (Doc. No. 13.)

On August 2, 2011, the Court held a hearing to determine the citizenship of Plaintiff. The Amended Complaint alleges only that Plaintiff "resides" in Pennsylvania, without indicating whether Plaintiff is a United States citizen. Defendants challenged this residency by attaching as exhibits to the Notice of Removal transcripts of prior court proceedings in which Plaintiff was a party. (See Doc. No. 1, Exs. 3-5.) These exhibits show that Plaintiff is a citizen of Greece. At the hearing to determine the citizenship of Plaintiff, counsel for Plaintiff failed to present any evidence to refute Defendants' contention that Plaintiff is a citizen of Greece. Based on this evidence and for reasons stated in the September 6, 2011 Opinion, this Court held that Plaintiff is a citizen of Greece. Moreover, at this hearing, Plaintiff's counsel raised for the first time the issue that Defendants, as residents of Pennsylvania, improperly removed this case to this Court under 28 U.S.C. 1441(b).

Plaintiff sought remand based on the "forum defendant rule." The forum defendant rule is codified in 28 U.S.C. § 1441(b), which provides that where the basis for removal is diversity of citizenship jurisdiction, a defendant may not remove the case from a state court to a federal court where the defendant is a citizen. A motion to remand must be filed within 30 days of removal. 28 U.S.C. § 1447(c). Plaintiff did not file the motion within the 30-day time period. As noted, despite the Motion to Remand being untimely filed, Plaintiff asked the Court to extend the 30-day requirement because of "excusable neglect" under Rule 6(b)(1)(B) of the Federal Rules of Civil Procedure. In the Second Motion to Remand, Plaintiff asked the Court again to remand the case to state court, and to delay ruling on the citizenship of Plaintiff until deciding whether the "forum defendant rule" precludes removal here.

Plaintiff Anastasios Papadopolous is a Greek citizen residing in King of Prussia, Pennsylvania. (Am. Compl., Doc. No. 10 ¶ 2.) Plaintiff was an officer, director, and stockholder of Corinthian Marble and Tile, Inc. ("Corinthian"). (Id. ¶¶ 4-6.) Plaintiff, Corinthian, and the remaining Corinthian shareholders retained Defendant Peter Mylonas to draft a Stockholders' Agreement. (Doc. No. 3, Ex. 2) ("the Agreement"); (Doc. No. 10, ¶¶ 11-12, 15-16.)

In the Amended Complaint, Plaintiff alleges that at some point after the Agreement was executed, Defendant Mylonas transferred Corinthian stock to two other shareholders without his consent. Plaintiff claims that this stock transfer violated a restrictive covenant in the Agreement, which provides, in pertinent part, as follows:

No stockholder shall sell, assign, mortgage, pledge or otherwise transfer or encumber the shares of the stock of the COMPANY now owned or hereafter acquired by him without the prior written UNANIMOUS consent of all the other STOCKHOLDERS.

(Id. ¶ 16.) As a result of the stock transfer, Plaintiff alleges he "was constructively and explicitly removed from his role as director and secretary of the corporation and his interest and control of the corporation was extinguished." (Id. ¶ 31.)

On March 21, 2011, Plaintiff filed a Writ of Summons in the Philadelphia County Court of Common Pleas. On May 19, 2011, Plaintiff filed his initial Complaint in state court, alleging one count of professional negligence against Defendant Mylonas and his law firm Peter G. Mylonas, P.C. On June 27, 2011, Defendants filed the Notice of Removal to this Court pursuant to 28 U.S.C. § 1441. (Doc. No. 1.) Defendants asserted diversity of citizenship jurisdiction pursuant to 28 U.S.C. § 1332 as the basis for the Court's subject matter jurisdiction. (Id. ¶ 5.)

On July 1, 2011, Defendants filed a Motion to Dismiss, arguing that the Complaint failed to state a claim upon which relief can be granted. (Doc. No. 3.) On July 22, 2011, Plaintiff filed an Amended Complaint (Doc. No. 4) and a Response in Opposition to the Motion to Dismiss (Doc. No. 5). On July 25, 2011, the Motion to Dismiss was denied as moot in light of the filing of the Amended Complaint. (Doc. No. 6.) That same day, the Court granted Plaintiff's Request for Leave to File of Record the revised Amended Complaint and additional exhibits (Doc. No. 7), which were filed on August 1, 2011. (Doc. No. 10.)

Plaintiff initially filed an Amended Complaint on July 22, 2011. (Doc. No. 4.) Plaintiff then requested leave to file a revised Amended Complaint with exhibits, which the Court granted. On August 1, 2011, Plaintiff filed the revised Amended Complaint with exhibits. (Doc. No. 10.) The Court is referring to the revised Amended Complaint in this Opinion.

Because the citizenship of Plaintiff was not evident in the Amended Complaint, the Court ordered the parties to appear for a hearing to determine the citizenship of Plaintiff and the subject matter jurisdiction of the Court. (Doc. No. 8.) On August 2, 2011, the Court held a hearing, where Defendants presented evidence that Plaintiff is a citizen of Greece. Plaintiff failed to present any evidence to the contrary. At the hearing, Plaintiff also made the oral Motion to Remand, arguing for the first time that the "forum defendant rule" of 28 U.S.C. § 1441(b) prohibits removal to this Court sitting in the Eastern District of Pennsylvania because Defendants are citizens of the forum state, which is Pennsylvania, the state in which Plaintiff filed the Complaint. Under these circumstances, Defendants would be barred from removing the case based on diversity of citizenship jurisdiction. On August 3, 2011, Plaintiff filed a written Motion to Remand based on the "forum defendant rule." (Doc. No. 11.) One week later, Plaintiff filed a Second Motion to Remand requesting that the Court decide the outstanding Motion to Remand prior to determining the citizenship of Plaintiff. (Doc. No. 13.)

On August 17, 2011, Defendants filed Responses in Opposition to both Motions to Remand. (Doc. Nos. 14 15.) Defendants asserted that the "forum defendant rule" is procedural in nature and does not concern the subject matter jurisdiction of the Court. Therefore, according to Defendants, a Motion to Remand based on this rule must be made by motion no later than 30 days after the filing of the Notice of Removal. In this case, the date of removal was June 27, 2011. Plaintiff first made the Motion to Remand at the hearing on August 2, 2011, more than 30 days after the filing of the Notice of Removal. On August 3, 2011, Plaintiff filed the written Motion to Remand. Thus, as Defendants have argued, the Motion to Remand was untimely filed. With respect to Plaintiff's request that the Court decide the Motion to Remand prior to determining the citizenship of Plaintiff, Defendants asserted that because the citizenship of Plaintiff is critical to the Court's diversity of citizenship jurisdiction, the citizenship of Plaintiff must be determined initially.

In the September 6, 2011 Opinion, this Court agreed with Defendants that it must determine the citizenship of Plaintiff to establish subject matter jurisdiction. Thus, the Court in effect denied Plaintiff's request that the Court consider the Motion to Remand prior to determining the citizenship of Plaintiff. Further, the Court agreed with Defendants that the "forum defendant rule" is procedural in nature and does not concern the subject matter jurisdiction of the Court. The Court found that a Motion to Remand was not filed within 30 days after the filing of the Notice of Removal and was therefore untimely.

Although the Motion was untimely, the Court determined that Plaintiff made a showing of "excusable neglect" pursuant to Rule 6(b)(1)(B) of the Federal Rules of Civil Procedure, which provides:

(1) When an act may or must be done within a specified time, the court may, for good cause, extend the time:
* * *
(B) on motion made after the time has expired if the party failed to act because of excusable neglect.

Specifically, Plaintiff's counsel represented that he missed the 30-day filing deadline because his offices were "in a state of flux" during an office move. (Doc. No. 17.) Because of this showing by Plaintiff's counsel, the Court found "excusable neglect" and granted Plaintiff's Motion to Remand. (Doc. Nos. 17 18.)

Thereafter, Defendants filed the Motion for Reconsideration. (Doc. No. 19.) Defendants made two arguments in support of the Motion. First, they argued that no legal authority allows the extension of the 30-day filing deadline set forth in 28 U.S.C. § 1447(c). Second, they contended that "Plaintiff's representation to this Court that his counsel was unable to file a Motion for Remand due to an offices [sic] move is . . . contradicted by counsel's filings in other lawsuits." (Doc. No. 19 at 5.) In a Response made on September 26, 2011 to the latter contention, Plaintiff's counsel asserted that his offices were "still in a state of flux." (Doc. No. 20 at 3.) On October 11, 2011, the Court granted Defendants' Motion for Reconsideration. (Doc. Nos. 21 22.)

However, on October 13, 2011, upon becoming aware that a certified copy of the Court's September 6, 2011 Order granting remand was sent by the Clerk of Court to the Court of Common Pleas of Philadelphia County, the Court directed counsel for all parties to submit memoranda of law regarding whether this Court had jurisdiction to decide the motion for reconsideration once the certified copy of the September 6, 2011 Order was sent to the clerk of state court. (Doc. No. 23.) Defendants maintain that this Court possessed legal authority to reconsider the Order remanding the case to state court and that the reconsideration Order reversing the remand Order should be allowed to stand. (Doc. No. 24 at 2.) Plaintiff, on the other hand, argues that the Court did not have jurisdiction to decide the Motion for Reconsideration once a certified copy of the Order remanding the case had been sent by the Clerk of Court to the Court of Common Pleas of Philadelphia County. (Doc. No. 25 at 2.) Considering the arguments of both parties, as well as clear Third Circuit precedent, the Court is persuaded that it had no jurisdiction to grant Defendants' Motion for Reconsideration and therefore the Order of October 11, 2011 will be vacated.

III. DISCUSSION

"The mailing of a remand order divests the district court of jurisdiction when the remand is authorized by [ 28 U.S.C. §] 1447(c)." Hudson United Bank v. LiTenda Mortgage Corp., 142 F.3d 151, 159 (3d Cir. 1998). As the Third Circuit noted in Trans Penn Wax Corp. v. McCandless:

The general rule is that a district court loses jurisdiction over a case once it has completed the remand by sending a certified copy of the remand order to the state court. See Hunt v. Acromed Corp, 961 F.2d 1079, 1081 (3d Cir. 1992). This view is premised on both the language of § 1447(c) and (d) and the need to establish a determinable jurisdictional event after which the state court can exercise control over the case without fear of further federal interference. The district court is also barred from reconsidering its decision if the remand was under § 1447(c) and the case thereby falls under the bar of § 1447(d). See, e.g., New Orleans Public Serv., Inc. v. Majoue, 802 F.2d 166, 167 (5th Cir. 1986) (per curiam); FDIC v. Santiago Plaza, 598 F.2d 634, 636 (1st Cir. 1979) (per curiam). But the physical mailing of the certified copy is the key jurisdictional event to divest the district court of jurisdiction, because a remand order is not self-executing. Hunt, 961 F.2d at 1081 (citing Bucy v. Nevada Constr. Co., 125 F.2d 213 (9th Cir. 1942).
50 F.3d 217, 225 (3d Cir. 1995). Here, the Court remanded this case to the Court of Common Pleas of Philadelphia County pursuant to 28 U.S.C. § 1447(c). This section provides in pertinent part:

A motion to remand the case on the basis of any defect other than lack of subject matter jurisdiction must be made within 30 days after the filing of the notice of removal under section 1446(a). . . . A certified copy of the order of remand shall be mailed by the clerk to the clerk of the State court. The State court may thereupon proceed with such case.

Although the Motion to Remand in this case was untimely because it was first made orally at a hearing on August 2, 2011, which was about a week after the 30-day period had expired, the Court in its initial Opinion dated September 6, 2011 extended that period pursuant to Rule 6(b)(1)(B) of the Federal Rules of Civil Procedure for "excusable neglect." This extension did not change the fact that the Court was still remanding pursuant to § 1447(c). On September 7, 2011, the Clerk of this Court sent a certified copy of the remand Order to state court. Accordingly, this Court did not have jurisdiction to reconsider the Order remanding the case to state court once a certified copy of the Order was mailed, and the reconsideration Order must be vacated.

This decision may seem discomforting to Defendants because they desire to litigate their case in federal court and especially because the Court reconsidered and found no "excusable neglect" in the Opinion granting reconsideration. Defendants, however, will still have their day in court because they may defend this case in state court, as they have been doing since the certified copy of the September 6, 2011 Order granting remand was sent from the Clerk of this Court to the Court of Common Pleas of Philadelphia County. Attached to this Opinion as Exhibit "A" is a copy of the state court docket in this case. It shows that after September 9, 2011, when the Remand Order was received in state court, considerable case management was undertaken. Moreover, the claim of legal malpractice asserted in this case is a state cause of action, which the state court may appropriately resolve.

As implicitly noted above in Trans Penn Wax Corp., no case should be bounced between state and federal court. 50 F.3d 217, 225. A determinable jurisdictional event is necessary so that "the state court can exercise control over the case without fear of further federal interference." Id. As noted, that event is the mailing of the certified copy of the remand Order to the clerk of the State court.

IV. CONCLUSION

For the above reasons, the Court will vacate its Order granting the Motion for Reconsideration.

EXHIBIT A Civil Docket Report

Case Description

Case ID: Case Caption: Filing Date: Court: Location: Jury: Case Type: Status: 110302078 PAPADOPOULOS VS MYLONAS Monday, March 21st, 2011 JS — MAJOR JURY-STANDARD CH — City Hall J — JURY 4L — MALPRACTICE — LEGAL CLLSC — LISTED FOR SETTLEMENT CONF

Related Cases

No related cases were found.

Case Event Schedule

Event Date/Time Room Location Judge PROJECTED 02-JUL-2012 City Courtroom MANFREDI, WILLIAM J SETTLEMENT CONF 09:00 AM Hall 646, City Hall DATE PROJECTED PRE- 04-SEP-2012 City Courtroom MANFREDI, WILLIAM J TRIAL CONF. DATE 09:00 AM Hall 646, City Hall PROJECTED TRIAL 01-OCT-2012 City Courtroom MANFREDI, WILLIAM J DATE 09:00 AM Hall 646, City Hall

Case motions

No case motions were found.

Case Parties

Seq # Assoc Expn Type ID Name Date Address: Aliases: none Address: Aliases: Address: Aliases: none Address: Aliases: none Address: Aliases: none Address: Aliases: none Address: Aliases: none 1 ATTORNEY A208494 MALOFIY, FRANCIS FOR PLAINTIFF FRANCIS ALEXANDER, LLC THE BEASLEY BUILDING 1125 WALNUT STREET PHILADELPHIA PA 19107 (215) 500-1000 2 1 PLAINTIFF @6918682 PAPADOPOULOS, ANASTASIOS 815 WEST DEKALB PAPADOPOULOS, TASOS PIKE KING OF PRUSSIA PA 19046 3 6 DEFENDANT @6918683 MYLONAS, PETER G 2725 W. CHESTER PIKE BROOMALL PA 19008 4 TEAM LEADER J280 MANFREDI, WILLIAM J 510 CITY HALL PHILADELPHIA PA 19107 (215) 686-2606 5 6 ADDITIONAL @6964244 LAW OFFICES OF DEFENDANT PETER G. MYLONAS, P.C. 2725 WEST CHESTER PIKE BROOMALL PA 19008 6 ATTORNEY A80206 MCDEVITT, WILLIAM F FOR DEFENDANT CHRISTIE PABARUE MORTENSEN AND YOUNG PC 1880 JFK BOULEVARD, 10TH FLOOR PHILADELPHIA PA 19103 (215) 587-1654 7 6 ATTORNEY A53714 BOGUTZ, MARC L FOR DEFENDANT 1880 JOHN F KENNEDY BLVD 10TH FLOOR PHILADELPHIA PA 19103 (215) 587-1687

Docket Entries

Filing Docket Type Filing Party Disposition Approval/ Date/Time Amount Entry Date Docket Entry: Docket none. Entry: Docket Entry: Docket none. Entry: Docket Entry: Docket none. Entry: Docket Entry: Docket Entry: Docket Entry: Docket Entry: Docket none. Entry: Docket none. Entry: Docket Entry: Docket none. Entry: Docket none. Entry: Docket Entry: Docket Entry: Docket none. Entry: Docket none. Entry: Docket none. Entry: Docket Entry: Docket Entry: Docket Entry: Docket Entry: Docket none. Entry: Docket Entry: Docket none. Entry: Docket none. Entry: Docket none. Entry: Docket Entry: Docket none. Entry: Docket Entry: Docket Entry: Docket none. Entry: Docket none. Entry: Docket none. Entry: Docket Entry: 21-MAR-2011 ACTIV — ACTIVE CASE 21-MAR-2011 03:45 PM 03:54 PM E-Filing Number: 1103034305 21-MAR-2011 CIVIJ — COMMENCEMENT MALOFIY, 21-MAR-2011 03:45 PM CIVIL ACTION JURY FRANCIS 03:54 PM 21-MAR-2011 WRSUM — PRAE TO ISSUE MALOFIY, 21-MAR-2011 03:45 PM WRIT OF SUMMONS FRANCIS 03:54 PM PRAECIPE TO ISSUE WRIT OF SUMMONS FILED. WRIT OF SUMMONS ISSUED. 21-MAR-2011 SSCG1 — SHERIFF'S MALOFIY, 21-MAR-2011 03:45 PM SURCHARGE 1 DEFT FRANCIS 03:54 PM 21-MAR-2011 JURYT — JURY TRIAL MALOFIY, 21-MAR-2011 03:45 PM PERFECTED FRANCIS 03:54 PM 12 JURORS REQUESTED. 21-MAR-2011 CLWCM — WAITING TO MALOFIY, 21-MAR-2011 03:45 PM LIST CASE MGMT CONF FRANCIS 03:54 PM 21-MAR-2011 CRMRT — CERTIFICATE MALOFIY, 21-MAR-2011 03:54 PM OF MERIT FRANCIS 12:00 AM CERTIFICATE OF MERIT AS TO DEFT PETER G MYLONAS ESQUIRE IS FILED 19-APR-2011 WRSUR — PRAECIPE TO MALOFIY, 20-APR-2011 10:51 PM REISSUE SUMMONS FRANCIS 07:08 AM PREACIPE TO REISSUE WRIT OF SUMMONS FILED. WRIT REISSUED. (FILED ON BEHALF OF ANASTASIOS PAPADOPOULOS) 19-MAY-2011 CMPLT — COMPLAINT MALOFIY, 20-MAY-2011 11:58 PM FILED NOTICE GIVEN FRANCIS 07:07 AM COMPLAINT WITH NOTICE TO DEFEND WITHIN TWENTY (20) DAYS AFTER SERVICE IN ACCORDANCE WITH RULE 1018.1 FILED. (FILED ON BEHALF OF ANASTASIOS PAPADOPOULOS) 20-MAY-2011 WRJAD — PRAECIPE — MALOFIY, 20-MAY-2011 03:01 AM WRIT TO JOIN FRANCIS 07:09 AM PRAECIPE TO ISSUE WRIT TO JOIN ADDITIONAL DEFENDANT LAW OFFICES OF PETER G. MYLONAS, P.C.. WRIT ISSUED. (FILED ON BEHALF OF ANASTASIOS PAPADOPOULOS) 01-JUN-2011 CLLCM — LISTED FOR 01-JUN-2011 05:11 PM CASE MGMT CONF 05:11 PM 03-JUN-2011 CLNGV — NOTICE GIVEN 03-JUN-2011 12:32 AM 12:32 AM 15-JUN-2011 ENAPP — ENTRY OF MCDEVITT, 15-JUN-2011 12:52 PM APPEARANCE FILED WILLIAM F 12:53 PM ENTRY OF APPEARANCE OF WILLIAM F MCDEVITT AND MARC L BOGUTZ FILED. (FILED ON BEHALF OF LAW OFFICES OF PETER G. MYLONAS, P.C. AND PETER G MYLONAS) 17-JUN-2011 CLNGV — NOTICE GIVEN 17-JUN-2011 12:32 AM 12:32 AM 21-JUN-2011 CLCCC — CASE MGMT SALTER, 21-JUN-2011 04:03 PM CONFERENCE PAUL 04:03 PM COMPLETED 21-JUN-2011 CMOIS — CASE 21-JUN-2011 04:03 PM MANAGEMENT ORDER 04:03 PM ISSUED CASE MANAGEMENT ORDER STANDARD TRACK — AND NOW, 21- JUN-2011, it is Ordered that: 1. The case management and time standards adopted for standard track cases shall be applicable to this case and are hereby incorporated into this Order. 2. All discovery on the above matter shall be completed not later than 04-JUN-2012. 3. Plaintiff shall identify and submit curriculum vitae and expert reports of all expert witnesses intended to testify at trial to all other parties not later than 04-JUN-2012. 4. Defendant and any additional defendants shall identify and submit curriculum vitae and expert reports of all expert witnesses intended to testify at trial not later than 02-JUL-2012. 5. All pre-trial motions shall be filed not later than 02-JUL-2012. 6. A settlement conference may be scheduled at any time after 02-JUL-2012. Prior to the settlement conference all counsel shall serve all opposing counsel and file a settlement memorandum containing the following: (a) A concise summary of the nature of the case if plaintiff or of the defense if defendant or additional defendant; (b) A statement by the plaintiff or all damages accumulated, including an itemization of injuries and all special damages claimed by categories and amount; (c) Defendant shall identify all applicable insurance carriers, together with applicable limits of liability. 7. A pre-trial conference will be scheduled any time after 04-SEP-2012. Fifteen days prior to pre-trial conference, all counsel shall serve all opposing counsel and file a pre-trial memorandum containing the following: (a) A concise summary of the nature of the case if plaintiff or the defense if defendant or additional defendant; (b) A list of all witnesses who may be called to testify at trial by name and address. Counsel should expect witnesses not listed to be precluded from testifying at trial; (c) A list of all exhibits the party intends to offer into evidence. All exhibits shall be pre- numbered and shall be exchanged among counsel prior to the conference. Counsel should expect any exhibit not listed to be precluded at trial; (d) Plaintiff shall list an itemization of injuries or damages sustained together with all special damages claimed by category and amount. This list shall include as appropriate, computations of all past lost earnings and future lost earning capacity or medical expenses together with any other unliquidated damages claimed; and (e) Defendant shall state in position regarding damages and shall identify all applicable insurance carriers, together with applicable limits of liability; (f) Each counsel shall provide an estimate of the anticipated length of trial. 8. It is expected that the case will be ready for trial 01-OCT-2012, and counsel should anticipate trial to begin expeditiously thereafter. 9. All counsel are under a continuing obligation and are hereby ordered to serve a copy of this order upon all unrepresented parties and upon all counsel entering an appearance subsequent to the entry of this order. . . . BY THE COURT: WILLIAM MANFREDI, J. 21-JUN-2011 ZR236 — NOTICE GIVEN 05-JUL-2011 04:03 PM UNDER RULE 236 02:28 PM NOTICE GIVEN ON 05-JUL-2011 OF CASE MANAGEMENT ORDER ISSUED ENTERED ON 21-JUN-2011. 21-JUN-2011 CLLSC — LISTED FOR 21-JUN-2011 04:03 PM SETTLEMENT CONF 04:03 PM 21-JUN-2011 CLLPT — LISTED FOR PRE- 21-JUN-2011 04:03 PM TRIAL CONF 04:03 PM 21-JUN-2011 CLLTR — LISTED FOR 21-JUN-2011 04:03 PM TRIAL 04:03 PM 21-JUN-2011 PROBJ — PRELIMINARY MCDEVITT, 22-JUN-2011 04:51 PM OBJECTIONS WILLIAM F 09:04 AM 63-11062863 PRELIMINARY OBJECTIONS TO PLAINITFF'S COMPLAINT FILED. RESPONSE DATE: 07/12/2011 (FILED ON BEHALF OF LAW OFFICES OF PETER G. MYLONAS, P.C. AND PETER G MYLONAS) 28-JUN-2011 RMEDC — NOT OF MCDEVITT, 28-JUN-2011 04:13 PM REMOVAL TO US DIST CT WILLIAM F 04:32 PM NOTICE OF REMOVAL TO THE U.S. (EASTERN) DISTRICT COURT UNDER 11-CV-04163-JHS. (FILED ON BEHALF OF LAW OFFICES OF PETER G. MYLONAS, P.C. AND PETER G MYLONAS) 14-JUL-2011 PODAM — PRELIM 14-JUL-2011 10:22 AM OBJECTIONS-MARKED 10:22 AM MOOT 63-11062863 NOTICE OF REMOVAL TO THE U.S. (EASTERN) DISTRICT COURT UNDER 11-CV-04163-JHS. (FILED ON BEHALF OF LAW OFFICES OF PETER G. MYLONAS, P.C. AND PETER G MYLONAS) 28-JUL-2011 RCDML — RECORD 28-JUL-2011 09:31 AM MAILED/TRANSMITTED 12:00 AM RECORDS MAILED TO U.S. DISTRICT COURT. UPS# 1Z 5E3 003 03 1016 1003. P.M. 01-AUG-2011 RRECP — RETURN 01-AUG-2011 04:23 PM RECEIPT RECEIVED 12:00 AM 09-SEP-2011 RMUSC — REMANDED BY 09-SEP-2011 11:55 AM US DISTRICT COURT 12:00 AM ORDERED THAT THIS CASE IS REMANDED TO THE COURT OF COMMON PLEAS OF PHILADELPHIA ON 9/9/11 UNDER 11-CV-4163. NO RECORDS RETURNED. P.M. 21-SEP-2011 CLWCM — WAITING TO 21-SEP-2011 10:36 AM LIST CASE MGMT CONF 12:00 AM 23-SEP-2011 CLLCM — LISTED FOR 23-SEP-2011 09:28 AM CASE MGMT CONF 09:28 AM 27-SEP-2011 CLNGV — NOTICE GIVEN 27-SEP-2011 12:33 AM 12:33 AM 10-OCT-2011 MTEXR — MOT-FOR MCDEVITT, 12-OCT-2011 04:58 PM EXTRAORDINARY RELIEF WILLIAM F 10:47 AM 71-11100971 RESPONSE DATE 10/24/2011. (FILED ON BEHALF OF LAW OFFICES OF PETER G. MYLONAS, P.C. AND PETER G MYLONAS) 11-OCT-2011 CLCCC — CASE MGMT SULLIVAN, 11-OCT-2011 04:07 PM CONFERENCE JOAN 04:07 PM COMPLETED 11-OCT-2011 CMOIS — CASE 11-OCT-2011 04:07 PM MANAGEMENT ORDER 04:07 PM ISSUED CASE MANAGEMENT ORDER STANDARD TRACK — AND NOW, 11- OCT-2011, it is Ordered that: 1. The case management and time standards adopted for standard track cases shall be applicable to this case and are hereby incorporated into this Order. 2. All discovery on the above matter shall be completed not later than 04-JUN-2012. 3. Plaintiff shall identify and submit curriculum vitae and expert reports of all expert witnesses intended to testify at trial to all other parties not later than 04-JUN-2012. 4. Defendant and any additional defendants shall identify and submit curriculum vitae and expert reports of all expert witnesses intended to testify at trial not later than 02-JUL-2012. 5. All pre-trial motions shall be filed not later than 02-JUL-2012. 6. A settlement conference may be scheduled at any time after 02-JUL-2012. Prior to the settlement conference all counsel shall serve all opposing counsel and file a settlement memorandum containing the following; (a) A concise summary of the nature of the case if plaintiff or of the defense if defendant or additional defendant; (b) A statement by the plaintiff or all damages accumulated, including an itemization of injuries and all special damages claimed by categories and amount; (c) Defendant shall identify all applicable insurance carriers, together with applicable limits of liability. 7. A pre-trial conference will be scheduled any time after 04-SEP-2012. Fifteen days prior to pre-trial conference, all counsel shall serve all opposing counsel and file a pre-trial memorandum containing the following: (a) A concise summary of the nature of the case if plaintiff or the defense if defendant or additional defendant; (b) A list of all witnesses who may be called to testify at trial by name and address. Counsel should expect witnesses not listed to be precluded from testifying at trial; (c) A list of all exhibits the party intends to offer into evidence. All exhibits shall be pre- numbered and shall be exchanged among counsel prior to the conference. Counsel should expect any exhibit not listed to be precluded at trial; (d) Plaintiff shall list an itemization of injuries or damages sustained together with all special damages claimed by category and amount. This list shall include as appropriate, computations of all past lost earnings and future lost earning capacity or medical expenses together with any other unliquidated damages claimed; and (e) Defendant shall state in position regarding damages and shall identify all applicable insurance carriers, together with applicable limits of liability; (f) Each counsel shall provide an estimate of the anticipated length of trial. 8. It is expected that the case will be ready for trial 01-OCT-2012, and counsel should anticipate trial to begin expeditiously thereafter. 9. All counsel are under a continuing obligation and are hereby ordered to serve a copy of this order upon all unrepresented parties and upon all counsel entering an appearance subsequent to the entry of this order. . . . BY THE COURT: WILLIAM MANFREDI, J. 11-OCT-2011 ZR236 — NOTICE GIVEN 13-OCT-2011 04:07 PM UNDER RULE 236 02:39 PM NOTICE GIVEN ON 13-OCT-2011 OF CASE MANAGEMENT ORDER ISSUED ENTERED ON 11-OCT-2011. 11-OCT-2011 CLLSC — LISTED FOR 11-OCT-2011 04:07 PM SETTLEMENT CONF 04:07 PM 11-OCT-2011 CLLPT — LISTED FOR PRE- 11-OCT-2011 04:07 PM TRIAL CONF 04:07 PM 11-OCT-2011 CLLTR — LISTED FOR 11-OCT-2011 04:07 PM TRIAL 04:07 PM 12-OCT-2011 MTWTD — MCDEVITT, 12-OCT-2011 01:53 PM MOTION/PETITION WILLIAM F 04:24 PM WITHDRAWN 71-11100971 PRAECIPE TO WITHDRAW MOT-FOR EXTRAORDINARY RELIEF FILED. (FILED ON BEHALF OF LAW OFFICES OF PETER G. MYLONAS, P.C. AND PETER G MYLONAS)


Summaries of

Papadopoulous v. Mylonas

United States District Court, E.D. Pennsylvania
Oct 31, 2011
CIVIL ACTION NO. 11-4163 (E.D. Pa. Oct. 31, 2011)
Case details for

Papadopoulous v. Mylonas

Case Details

Full title:ANASTASIOS PAPADOPOULOUS, Plaintiff, v. PETER G. MYLONAS, et al.…

Court:United States District Court, E.D. Pennsylvania

Date published: Oct 31, 2011

Citations

CIVIL ACTION NO. 11-4163 (E.D. Pa. Oct. 31, 2011)