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Photo of Cuyahoga County

Court

Cuyahoga County

Ohio

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Case Information

Filed 2025-03-12
Status ACTIVE
Type Tort M.v. Accident
Docket 99 entries

Parties

Plaintiff William Shannon|Jeannie Shannon
Defendant Federal Express Corporation Co Its Statutory Agent Ct Corporation System|Tjm Express, Inc. Co Its Statutory Agent Michael Kindelberger|Dominique Cooper
Photo of Hon. SHANNON M GALLAGHER

Judge

Hon. SHANNON M GALLAGHER

Cuyahoga County (OH)

Ohio

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Lawyers

Docket Entries

  1. CASE FILED: COMPLAINT
  2. NOTICE FILED BY DEFENDANT(S) FEDERAL EXPRESS CORPORATION(D1), TJM EXPRESS, INC.(D2) and DOMINIQUE COOPER(D3) ATTORNEY Y TIMOTHY CHAI 0092202 DEFENDANTS' NOTICE OF INTENT TO RESPOND TO PLAINTIFFS' SUBMISSION OF DOCUMENTATION IN SUPPORT OF REASONABLE ATTORNEY'S FEES, PURSUANT TO CIV.R.6(C)(1)
  3. BRIEF FILED BY PLAINTIFF(S) WILLIAM SHANNON(P1) and JEANNIE SHANNON(P2) SUSAN E PETERSEN 0069741 PLAINTIFFS' SUBMISSION OF DOCUMENTATION IN SUPPORT OF REQUEST FOR REASONABLE ATTORNEY'S FEES AND EXPENSES
  4. TELEPHONE CONFERENCE HELD ON 4/2/2026. PARTIES APPEARED THROUGH COUNSEL. DISCUSSIONS HAD REGARDING OUTSTANDING DISCOVERY PROPOUNDED UPON DEFENDANTS TJM AND FEDERAL EXPRESS. THE COURT SUPPLEMENTS ITS ENTRY, DATED 4/2/2026, GRANTING PLAINTIFFS' MOTION TO COMPEL DISCOVERY FROM DEFENDANT TJM: BY 4/8/2026, DEFENDANT TJM IS ORDERED TO EITHER PRODUCE ADDITIONAL DOCUMENTS RESPONSIVE TO THE FOLLOWING CATEGORIES OF DISCOVERY REQUESTS OR PRODUCE VERIFICATIONS THAT ITS PERSONNEL HAVE CONDUCTED A THOROUGH SEARCH AND CONFIRMED THAT THE FOLLOWING DOCUMENTS HAVE BEEN FULLY PRODUCED AND THERE REMAIN NO FURTHER RESPONSIVE DOCUMENTS WITHIN ITS POSSESSION, CUSTODY OR CONTROL: ANY ORGANIZATIONAL CHART AND SUPERVISORY CHAIN OF COMMAND PERTAINING TO TJM'S ORGANIZATIONAL STRUCTURE; AND ALL SAFETY MESSAGING TOPICS DISTRIBUTED TO TJM FROM FED EX DURING DEFENDANT COOPER'S EMPLOYMENT THROUGH THE DATE OF THE CRASH. AS INDICATED IN THE COURT'S ORDER PERTAINING TO THE HEARING ON 4/1/2026, THE COURT SETS THE FOLLOWING ADDITIONAL REQUIREMENTS FOR PRODUCTION: BY 4/8/2026, DEFENDANT FEDERAL EXPRESS IS ORDERED TO EITHER PRODUCE ADDITIONAL DOCUMENTS RESPONSIVE TO THE FOLLOWING CATEGORIES OF DISCOVERY REQUESTS OR PRODUCE VERIFICATIONS THAT ITS PERSONNEL HAVE CONDUCTED A THOROUGH SEARCH AND CONFIRMED THAT THE FOLLOWING DOCUMENTS HAVE BEEN FULLY PRODUCED AND THERE REMAIN NO FURTHER RESPONSIVE DOCUMENTS WITHIN ITS POSSESSION, CUSTODY OR CONTROL: COMPLETE, UNEDITED FULL-WORKDAY VEDR FOOTAGE FROM ALL CAMERA ANGLES ON 8/21/24; ALL ELECTRONIC COMMUNICATIONS WITH OR ABOUT COOPER ON 8/21/24, INCLUDING HUTCHERSON EMAIL CHAIN; POST-ACCIDENT DRUG AND ALCOHOL TESTING RECORDS, OR SWORN EXPLANATION OF DECISION NOT TO TEST, AND ANY AND ALL NON-PRIVILEGED COMMUNICATIONS REGARDING THE DECISION TO NOT CONDUCT POST-ACCIDENT DRUG AND ALCOHOL TESTING; FEDEX INTERNAL INVESTIGATION FILE FOR 8/21/24 INCIDENT; ALL DOCUMENTS PERTAINING TO MR. COOPER'S EMPLOYEE FILE, WHICH ARE LISTED AS REQUIREMENTS WITHIN THE REGULATIONS THAT BOTH TJM EXPRESS AND FEDERAL EXPRESS ARE REQUIRED TO KEEP ON FILE, GOING BACK TO NOVEMBER 2022, AND INCLUDING MR. COOPER'S SIGNED CERTIFICATION OF TRAFFIC VIOLATIONS AND THE ROAD TEST CERTIFICATE AND EVALUATION FROM COOPER'S CURATIVE TRAINING PROGRAM; ISPA GOVERNING COOPER'S TENURE AT PRO DELIVERY, INC. FROM NOVEMBER 2022 TO MAY 2024; MYGROUNDBIZ TERMS INCORPORATED BY REFERENCE INTO ISPA 6.6(8); FEDEX INTERNAL INTRANET POLICIES REGARDING SAFETY COMPLIANCE, MVR REVIEW, AND DRIVER QUALIFICATION; SAMBA MVR-MONITORING RECORDS AND REAL-TIME ALERTS FOR MR. COOPER; COMPLETE SRI DATASET FOR TJM EXPRESS FROM AUGUST 2022 TO AUGUST 2024; ALL SAFETY MESSAGING PUSHED TO TJM DURING MR. COOPER'S EMPLOYMENT THROUGH AUGUST 21, 2024. BY 4/8/2026, DEFENDANT FEDERAL EXPRESS IS ORDERED TO PRODUCE FOR IN CAMERA INSPECTION TO THE COURT STAFF ATTORNEY, ANY DOCUMENTS WITHIN THE FED EX INTERNAL INVESTIGATION FILE FOR THE AUGUST 21, 2024 INCIDENT THAT IS ARGUED TO BE PRIVILEGE, PRODUCED WITH BATES STAMPED IDENTIFICATION NUMBERS, AND A PRIVILEGE LOG DENOTING ANY DOCUMENTS THAT DEFENDANT ARGUES ARE NOT SUBJECT TO PRODUCTION DUE TO PRIVILEGE. BY 4/7/2026, DEFENSE COUNSEL IS ORDERED TO DIRECTLY REQUEST FROM GROUND CLOUD ANY AND ALL TRAINING RECORDS FOR MR. COOPER, ALONG WITH ANY VIDEOS UTILIZED BY MR. COOPER DURING HIS EMPLOYMENT WITH DEFENDANTS TJM EXPRESS AND/OR FEDERAL EXPRESS. BY 4/8/2026, DEFENDANT FEDERAL EXPRESS TO PRODUCE THE FOLLOWING DOCUMENTS TO PLAINTIFFS: EXCESS AND UMBRELLA INSURANCE POLICIES, WITH REDACTIONS LIMITED TO PREMIUMS. BY 4/8/2026, DEFENDANT FEDERAL EXPRESS WILL SUPPLEMENT ITS RESPONSES TO INTERROGATORY NOS. 14 AND 29 WITH SPECIFIC, RELEVANT, AND NON-PRIVILEGED INFORMATION, IDENTIFYING SPECIFIC INDIVIDUALS RESPONSIBLE FOR DRIVER SAFETY, TRAINING, SUPERVISION, AND CRASH INVESTIGATION WITH HUB 445 FROM NOVEMBER 2022 TO THE PRESENT; AND INTERROGATORY NO. 19, PRIOR CIVIL LITIGATION INVOLVING FED EX DRIVERS OR CONTRACTORS FOR OHIO FROM AUGUST 2021 TO THE PRESENT. ANY DEFENDANTS' FAILURE TO COMPLY WITH THIS COURT'S DISCOVERY ORDERS GRANTING PLAINTIFFS' FOUR SEPARATE MOTIONS TO COMPEL MAY RESULT IN THE COURT GRANTING ADDITIONAL SANCTIONS, INCLUDING BUT NOT LIMITED TO PROHIBITING THE INTRODUCTION OF EVIDENCE AT TRIAL, LIMITING OR DISMISSAL OF CLAIMS AND/OR DEFENSES, GRANTING OF COSTS AND/OR ATTORNEYS FEES AND SUCH OTHER RELIEF AS THE COURT DEEMS APPROPRIATE. NOTICE ISSUED
  5. PLAINTIFFS' MOTION FOR SANCTIONS AND TO COMPEL DEPOSITIONS, FILED 2/20/2026, IS GRANTED. THE COURT ORDERS THE FOLLOWING: THAT PLAINTIFFS BE ENTITLED TO RE-DEPOSE MICHAEL SEAR AT PLAINTIFFS' COUNSEL'S OFFICES AT THE EXPENSE OF FEDERAL EXPRESS BY 4/17/2026; THAT DEFENDANTS PRODUCE THE FOLLOWING WITNESSES FOR DEPOSITION AT PLAINTIFFS' COUNSEL'S OFFICES; ROBERT COLICK, JAMES HUTCHERSON, MATT THOMAS, MIKE KINDELBERGER, TOM MCCARTHY, AND ANY OTHER WITNESSES IDENTIFIED IN DEFENDANTS' INTERROGATORY RESPONSES WHOSE DEPOSITIONS HAVE BEEN REQUESTED BUT NOT PROVIDED BY 4/17/2026; AND THAT ALL FUTURE DEPOSITIONS OF DEFENDANTS' WITNESSES BE CONDUCTED IN PERSON AT PLAINTIFFS' COUNSEL'S OFFICES. THE COURT WILL CONSIDER JOINT REQUESTS TO CONTINUE FUTURE DEADLINES IN ORDER TO FACILITATE ADDITIONAL DISCOVERY. PLAINTIFF IS AWARDED SANCTIONS AGAINST DEFENDANT FEDERAL EXPRESS AND ITS ATTORNEYS FOR THE REASONABLE EXPENSES CAUSED BY THE FEBRUARY 19, 2026 DEPOSITION OF MICHAEL SEAR, INCLUDING COURT REPORTER AND VIDEOGRAPHER FEES, AND ATTORNEY/PARALEGAL TIME ATTRIBUTABLE TO THE REMOTE FORMAT AND RESULTING DELAYS, AND PLAINTIFFS' REASONABLE ATTORNEY FEES FOR THE COSTS OF PREPARING THIS MOTION TO COMPEL. PLAINTIFFS TO SUBMIT DOCUMENTATION IN SUPPORT OF THEIR REQUEST FOR REASONABLE ATTORNEYS FEES AND EXPENSES BY 4/10/2026. NOTICE ISSUED
  6. ANSWER FILED BY D3 DOMINIQUE COOPER ATTORNEY Y TIMOTHY CHAI 0092202 ANSWER OF DEFENDANT DOMINIQUE COOPER TO FIRST AMENDED COMPLAINT
  7. ANSWER FILED BY D2 TJM EXPRESS, INC. ATTORNEY Y TIMOTHY CHAI 0092202 ANSWER OF DEFENDANT TJM EXPRESS TO FIRST AMENDED COMPLAINT
  8. ANSWER FILED BY D1 FEDERAL EXPRESS CORPORATION ATTORNEY Y TIMOTHY CHAI 0092202 ANSWER OF DEFENDANT FEDEX EXPRESS TO FIRST AMENDED COMPLAINT
  9. PLAINTIFF'S MOTION TO COMPEL DISCOVERY FROM DEFENDANT DOMINIQUE COOPER, FILED 3/10/2026, IS GRANTED. DEFENDANT COOPER IS ORDERED TO PRODUCE THE FOLLOWING RESPONSES TO PLAINTIFFS' DISCOVERY REQUESTS BY 4/8/2026: COMPLETE CELL PHONE RECORDS FOR AUGUST 21, 2024, INCLUDING ALL CALL LOGS, TEXT MESSAGE LOGS, AND DATA RECORDS; AND A SIGNED AND DATED VERIFICATION SUPPLEMENTAL ANSWER TO INTERROGATORY NO. 10, INCORPORATING EACH ADMISSION MADE IN HIS FEBRUARY 26, 2026 RFA RESPONSES. BY 4/8/2026, DEFENDANT COOPER IS ORDERED TO PRODUCE FOR IN CAMERA INSPECTION TO THE COURT STAFF ATTORNEY, THE COMPLETE AND UNREDACTED COOPER-THOMAS COMMUNICATION HISTORY FROM MAY 2024 TO MARCH 1, 2025, PRODUCED WITH BATE STAMPED IDENTIFICATION NUMBERS, AND A PRIVILEGE LOG DENOTING ANY COMMUNICATIONS THAT DEFENDANT ARGUES ARE NOT SUBJECT TO PRODUCTION. BY 4/8/2026, DEFENDANT COOPER IS ORDERED TO PRODUCE VERIFICATIONS THAT HE HAS CONDUCTED A THOROUGH SEARCH AND CONFIRMED THAT THE FOLLOWING DOCUMENTS HAVE BEEN FULLY PRODUCED AND THERE REMAIN NO FURTHER RESPONSIVE DOCUMENTS WITHIN HIS POSSESSION, CUSTODY OR CONTROL: ALL EMPLOYER-PROVIDED HANDBOOKS, TRAINING ACKNOWLEDGMENTS, SAFETY GUIDELINES, AND DIGITAL TRAINING MATERIALS FROM TJM, FEDEX, JFT PRO DELIVERY, OR ANY OTHER PRIOR EMPLOYER; ALL ROUTE, MANIFEST, AND GROUNDCLOUD RECORDS ACCESSIBLE TO COOPER FOR AUGUST 21, 2024; AND A SWORN CERTIFICATION IDENTIFYING EVERY DEVICE, ACCOUNT, AND REPOSITORY SEARCHED AND CONFIRMING THAT NO RESPONSIVE COMMUNICATIONS HAVE BEEN DELETED. THE COURT GRANTS PLAINTIFFS' REQUEST FOR REASONABLE ATTORNEYS FEES AND EXPENSES RELATED TO THE PREPARATION OF THIS MOTION TO COMPEL AND THE REPLY IN SUPPORT. PURSUANT TO CIV. R. 37(A)(5)(A), THE COURT SHALL, AFTER GIVING AN OPPORTUNITY TO BE HEARD, REQUIRE THE PARTY OR DEPONENT WHOSE CONDUCT NECESSITATED THE MOTION, THE PARTY OR ATTORNEY ADVISING THAT CONDUCT, OR BOTH TO PAY THE MOVANT'S REASONABLE EXPENSES INCURRED IN MAKING THE MOTION, INCLUDING ATTORNEY'S FEES. THE COURT FURTHER FINDS THAT PLAINTIFFS DID ATTEMPT IN GOOD FAITH TO RESOLVE THE DISCOVERY DISPUTE WITHOUT COURT INTERVENTION, DEFENDANT'S RESPONSE IS NOT SUBSTANTIALLY JUSTIFIED GIVEN THE EXTREME DELAYS IN PRODUCING FULL DISCOVERY, AND THERE ARE NO OTHER CIRCUMSTANCES THAT WOULD MAKE AN AWARD UNJUST. THE SANCTIONS WILL BE AWARDED AGAINST BOTH DEFENDANT DOMINIQUE COOPER AND DEFENDANT'S ATTORNEYS. PLAINTIFFS TO SUBMIT DOCUMENTATION IN SUPPORT OF THEIR REQUEST FOR REASONABLE ATTORNEYS FEES AND EXPENSES BY 4/10/2026. NOTICE ISSUED
  10. PLAINTIFFS' MOTION TO COMPEL DISCOVERY FROM DEFENDANT TJM EXPRESS, INC., FILED 3/10/2026, IS GRANTED. DEFENDANT TJM IS ORDERED TO PRODUCE THE FOLLOWING RESPONSES TO PLAINTIFFS' DISCOVERY REQUESTS BY 4/8/2026: TJM'S PROTECTIVE INSURANCE POLICY; MATTHEW THOMAS'S PERSONNEL FILE; AND THE VEHICLE LEASE. BY 4/8/2026, DEFENDANT TJM IS ORDERED TO PRODUCE FOR IN CAMERA INSPECTION TO THE COURT STAFF ATTORNEY, THE COMPLETE, UNREDACTED "DOMINIQUE COOPER" CORRESPONDENCE FOLDER FROM MIKE KINDELBERGER'S COMPUTER, PRODUCED WITH BATES STAMPED IDENTIFICATION NUMBERS, AND A PRIVILEGE LOG DENOTING ANY COMMUNICATIONS THAT DEFENDANT ARGUES ARE NOT SUBJECT TO PRODUCTION. BY 4/8/2026, DEFENDANT TJM IS ORDERED TO PRODUCE VERIFICATIONS THAT ITS PERSONNEL HAVE CONDUCTED A THOROUGH SEARCH AND CONFIRMED THAT THE FOLLOWING DOCUMENTS HAVE BEEN FULLY PRODUCED AND THERE REMAIN NO FURTHER RESPONSIVE DOCUMENTS WITHIN ITS POSSESSION, CUSTODY OR CONTROL: THE FULL-DAY GROUND CLOUD DASHCAM SEQUENCE FROM ALL CAMERAS FROM AUGUST 21, 2024; TJM'S DRUG-AND-ALCOHOL PROGRAM RECORDS GOVERNING POST-ACCIDENT TESTING; ALL DOCUMENTS PERTAINING TO MR. COOPER'S EMPLOYEE FILE, WHICH ARE LISTED AS REQUIREMENTS WITHIN THE REGULATIONS THAT BOTH TJM EXPRESS AND FEDERAL EXPRESS ARE REQUIRED TO KEEP ON FILE. BY 4/3/2026, DEFENSE COUNSEL IS ORDERED TO DIRECTLY REQUEST FROM GROUND CLOUD ANY AND ALL TRAINING VIDEOS UTILIZED BY DEFENDANT COOPER DURING HIS EMPLOYMENT WITH DEFENDANTS TJM EXPRESS AND/OR FEDERAL EXPRESS. THE COURT GRANTS PLAINTIFFS' REQUEST FOR REASONABLE ATTORNEYS FEES AND EXPENSES RELATED TO THE PREPARATION OF THIS MOTION TO COMPEL AND THE REPLY IN SUPPORT. PURSUANT TO CIV. R. 37(A)(5)(A), THE COURT SHALL, AFTER GIVING AN OPPORTUNITY TO BE HEARD, REQUIRE THE PARTY OR DEPONENT WHOSE CONDUCT NECESSITATED THE MOTION, THE PARTY OR ATTORNEY ADVISING THAT CONDUCT, OR BOTH TO PAY THE MOVANT'S REASONABLE EXPENSES INCURRED IN MAKING THE MOTION, INCLUDING ATTORNEY'S FEES. THE COURT FURTHER FINDS THAT PLAINTIFFS DID ATTEMPT IN GOOD FAITH TO RESOLVE THE DISCOVERY DISPUTE WITHOUT COURT INTERVENTION, DEFENDANT'S RESPONSE IS NOT SUBSTANTIALLY JUSTIFIED GIVEN THE EXTREME DELAYS IN PRODUCING FULL DISCOVERY, AND THERE ARE NO OTHER CIRCUMSTANCES THAT WOULD MAKE AN AWARD UNJUST. THE SANCTIONS WILL BE AWARDED AGAINST BOTH DEFENDANT TJM AND DEFENDANT'S ATTORNEYS. PLAINTIFFS TO SUBMIT DOCUMENTATION IN SUPPORT OF THEIR REQUEST FOR REASONABLE ATTORNEYS FEES AND EXPENSES BY 4/10/2026. NOTICE ISSUED
  11. HEARING HELD ON 4/1/2026 TO ADDRESS ONGOING DISCOVERY DISPUTES AS BRIEFED IN PLAINTIFFS' FOUR MOTIONS TO COMPEL AND RELEVANT TO THIS COURT'S ORDER ON 3/19/2026 GRANTING PLAINTIFFS' RENEWED MOTION TO COMPEL, FILED 2/20/2026. PLAINTIFFS' COUNSEL SUSAN PETERSEN APPEARED. DEFENSE COUNSEL TIM CHAI AND MICHAEL BETHUNE APPEARED. COURT REPORTER CHRIS WHITFIELD. THE PARTIES PRESENTED OPENING STATEMENTS. PLAINTIFFS CALLED THE FOLLOWING WITNESSES TO PROVIDE TESTIMONY: DEFENDANT FEDERAL EXPRESS CORPORATION'S REPRESENTATIVE JIM FILOUS, DEFENDANT TJM EXPRESS, INC.'S REPRESENTATIVE MIKE KINDELBERGER, AND DEFENDANT DOMINIQUE COOPER. ON 3/19/2026, THE COURT GRANTED PLAINTIFFS' RENEWED MOTION TO COMPEL AND ORDERED DEFENDANT FEDERAL EXPRESS CORPORATION TO PRODUCE ALL OUTSTANDING DISCOVERY BY 3/27/2026. YET, IT IS APPARENT FROM THE EXTENSIVE BRIEFING ON THE DOCKET RELATED TO PLAINTIFFS' FOUR MOTIONS TO COMPEL, AS WELL AS THE ORAL ARGUMENTS AND WITNESS TESTIMONY PROVIDED AT THE HEARING, THAT ALL DEFENDANTS HAVE STILL FAILED TO TIMELY PRODUCE COMPLETE RESPONSES TO PLAINTIFFS' INITIAL DISCOVERY REQUESTS PROPOUNDED IN APRIL 2025, AND THAT THIS FAILURE TO PRODUCE HAS PREJUDICED PLAINTIFFS IN THEIR ABILITY TO PROSECUTE THEIR CASE AND HAS HINDERED PLAINTIFFS' ABILITY TO CONDUCT FOLLOW-UP DISCOVERY ON ISSUES RELEVANT TO THEIR CLAIMS. AS ONE EXAMPLE, PLAINTIFFS REQUESTED ALL TRAINING MATERIALS UTILIZED BY DEFENDANTS IN TRAINING DOMINIQUE COOPER FOR HIS JOB AS A DELIVERY DRIVER. PLAINTIFFS WERE NEVER PROVIDED THE TRAINING VIDEOS THAT MR. COOPER WATCHED DURING HIS TRAINING. PLAINTIFFS' COUNSEL WAS ADVISED, SEEMINGLY FOR THE FIRST TIME, ON 4/1/2026 THAT ANY TRAINING VIDEOS ARE WITHIN THE CUSTODY AND CONTROL OF A THIRD PARTY. DUE TO THE DELAY IN PROVIDING THIS INFORMATION, PLAINTIFFS MAY NOW BE UNABLE TO OBTAIN THESE TRAINING VIDEOS AND HAVE THEM REVIEWED BY PLAINTIFFS' EXPERT, GIVEN THAT PLAINTIFFS' EXPERT REPORT DEADLINE IS 4/10/2026. THE COURT IS WILLING TO CONTINUE FUTURE DEADLINES IN ORDER TO FACILITATE ADDITIONAL DISCOVERY IF REQUESTED BY THE PARTIES. PLAINTIFFS TO SUBMIT A SUPPLEMENTAL LIST OF ALL OUTSTANDING DISCOVERY YET TO BE PRODUCED BY FEDERAL EXPRESS CORPORATION BY 4/3/2026. COUNSEL FOR ALL PARTIES TO CONFER WITH THE COURT'S STAFF ATTORNEY TO REVIEW THE SUPPLEMENTAL LIST AND THEREAFTER THE COURT WILL SET FURTHER REQUIREMENTS FOR PRODUCTION. PLAINTIFFS' MOTION FOR SANCTIONS, FILED 2/20/2026, IS GRANTED. PURSUANT TO CIV. R. 37(A)(5)(A), THE COURT SHALL, AFTER GIVING AN OPPORTUNITY TO BE HEARD, REQUIRE THE PARTY OR DEPONENT WHOSE CONDUCT NECESSITATED THE MOTION, THE PARTY OR ATTORNEY ADVISING THAT CONDUCT, OR BOTH TO PAY THE MOVANT'S REASONABLE EXPENSES INCURRED IN MAKING THE MOTION, INCLUDING ATTORNEY'S FEES. DEFENDANTS ARGUE THAT THE COURT SHOULD DENY PLAINTIFFS' REQUEST FOR SANCTIONS BECAUSE PLAINTIFFS FAILED TO MEET AND CONFER WITH DEFENSE COUNSEL IN ORDER TO RESOLVE THE ISSUES PRIOR TO FILING THE RENEWED MOTIONS TO COMPEL. THIS ARGUMENT IS NOT PERSUASIVE GIVEN THAT THE ATTORNEYS HAVE HAD SIX TELEPHONE CONFERENCES WITH THE COURT STAFF ATTORNEY SINCE NOVEMBER 2025 IN AN ATTEMPT TO COME TO AN AGREEMENT ON DEFENDANTS' OUTSTANDING DISCOVERY RESPONSES, AND DEFENDANTS HAVE NOT YET PRODUCED COMPLETE RESPONSES TO PLAINTIFFS' INITIAL DISCOVERY REQUESTS, DESPITE THE COURT ORDERING FEDERAL EXPRESS TO FULLY RESPOND BY 3/27/2026. ACCORDINGLY, THE COURT WILL AWARD PLAINTIFFS REASONABLE ATTORNEYS FEES AND EXPENSES FOR THE TIME SPENT DRAFTING THE MOTION TO COMPEL, FILED 2/20/2026, AND THE REPLY BRIEF, FILED 3/13/2026, AND FOR APPEARING AT THE HEARING ON 4/1/2026. THE SANCTIONS WILL BE AWARDED AGAINST BOTH DEFENDANT FEDERAL EXPRESS CORPORATION AND DEFENDANT'S ATTORNEYS. PLAINTIFFS TO SUBMIT DOCUMENTATION IN SUPPORT OF THEIR REQUEST FOR REASONABLE ATTORNEYS FEES AND EXPENSES BY 4/10/2026. NOTICE ISSUED
  12. COURT REPORTER FEE
  13. NOTICE FILED BY PLAINTIFF(S) WILLIAM SHANNON(P1) and JEANNIE SHANNON(P2) ATTORNEY SUSAN E PETERSEN 0069741 PLAINTIFFS' NOTICE OF FILING RETURN OF SERVICE OF TRIAL SUBPOENA SERVED UPON JAMES HUTCHERSON
  14. NOTICE FILED BY PLAINTIFF(S) WILLIAM SHANNON(P1) and JEANNIE SHANNON(P2) ATTORNEY SUSAN E PETERSEN 0069741 PLAINTIFFS' NOTICE OF FILING RETURN OF SERVICE OF TRIAL SUBPOENA SERVED UPON ROBERT COLICK
  15. NOTICE FILED BY PLAINTIFF(S) WILLIAM SHANNON(P1) and JEANNIE SHANNON(P2) ATTORNEY SUSAN E PETERSEN 0069741 PLAINTIFFS' NOTICE OF FILING RETURN OF SERVICE OF TRIAL SUBPOENA SERVED UPON MATTHEW THOMAS
  16. REPLY BRIEF FILED BY PLAINTIFF(S) WILLIAM SHANNON(P1) and JEANNIE SHANNON(P2) SUSAN E PETERSEN 0069741 PLAINTIFFS' REPLY IN SUPPORT OF MOTION TO COMPEL DISCOVERY FROM DEFENDANT TJM EXPRESS, INC.
  17. REPLY BRIEF FILED BY PLAINTIFF(S) WILLIAM SHANNON(P1) and JEANNIE SHANNON(P2) SUSAN E PETERSEN 0069741 PLAINTIFF'S REPLY IN SUPPORT OF MOTION TO COMPEL DISCOVERY FROM DEFENDANT DOMINIQUE COOPER
  18. BRIEF IN OPPOSITION FILED BY D2 TJM EXPRESS, INC. Y TIMOTHY CHAI 0092202 TJM EXPRESS, INC. RESPONSE IN OPPOSITION TO PLAINTIFF'S MOTION TO COMPEL DISCOVERY
  19. BRIEF IN OPPOSITION FILED BY D3 DOMINIQUE COOPER Y TIMOTHY CHAI 0092202 DOMINIQUE COOPER RESPONSE IN OPPOSITION TO PLAINTIFF'S RENEWED MOTION TO COMPEL DISCOVERY AND REQUEST FOR SANCTIONS
  20. DEPOSIT AMOUNT PAID SUSAN E PETERSEN
  21. AMENDED COMPLAINT $75 PLAINTIFFS' FIRST AMENDED COMPLAINT
  22. PLAINTIFFS' RENEWED MOTION TO COMPEL DISCOVERY FROM DEFENDANT FEDERAL EXPRESS CORPORATION AND REQUEST FOR SANCTIONS UNDER CIV. R. 37 02/20/2026, IS GRANTED IN PART. DEFENDANT FEDEX TO PRODUCE ALL OUTSTANDING AND/OR INCOMPLETE DISCOVERY RESPONSES TO PLAINTIFFS' DISCOVERY REQUESTS PROPOUNDED ON DEFENDANT FEDEX IN APRIL 2025 AND FURTHER IDENTIFIED WITHIN PLAINTIFF'S MOTION TO COMPEL BY FRIDAY 3/27/2026. DEFENDANT FEDEX'S FAILURE TO PRODUCE ALL OUTSTANDING AND/OR INCOMPLETE DISCOVERY BY 3/27/2026 MAY RESULT IN SANCTIONS. THIS MATTER REMAINS SET FOR HEARING ON 4/1/2026 TO ADDRESS PLAINTIFF'S REQUEST FOR SANCTIONS REQUESTED PURSUANT TO CIV.R. 37(A)(5)(A), (B), AND (D); AND THE THREE OTHER PENDING MOTIONS TO COMPEL FILED IN THIS CASE. A REPRESENTATIVE OF DEFENDANT FEDEX IS ORDERED TO APPEAR IN PERSON FOR THE HEARING ON 4/1/2026 AT 9:00 A.M. NOTICE ISSUED
  23. PLAINTIFFS' MOTION FOR LEAVE TO FILE FIRST AMENDED COMPLAINT 02/17/2026, IS GRANTED. PLAINTIFFS TO FILE THE AMENDED COMPLAINT AS A NEW PLEADING BY 3/24/2026. NOTICE ISSUED
  24. NOTICE FILED BY P1 WILLIAM SHANNON ATTORNEY SUSAN E PETERSEN 0069741 PLAINTIFFS' NOTICE OF FILING RETURN OF SERVICE OF SUBPOENA SERVED UPON JIMMY HUTCHERSON
  25. NOTICE FILED BY P1 WILLIAM SHANNON ATTORNEY SUSAN E PETERSEN 0069741 PLAINTIFFS' NOTICE OF FILING RETURN OF SERVICE OF SUBPOENA SERVED UPON ROBERT COLICK
  26. FILED UNDER SEAL PLAINTIFF'S NOTICE OF FILING PROTECTED EXHIBITS
  27. FILDE UNDER SEAL PLAINTIFF'S NOTICE OF FILING EXCERPTS OF PLAINTIFFS' MOTION FOR LEAVE TO FILE FIRST AMENDED COMPLAINT C-1
  28. REPLY BRIEF FILED BY P1 WILLIAM SHANNON SUSAN E PETERSEN 0069741 PLAINTIFFS' REPLY IN SUPPORT OF RENEWED MOTION TO COMPEL DISCOVERY FROM DEFENDANT FEDERAL EXPRESS CORPORATION AND REQUEST FOR SANCTIONS UNDER CIV. R. 37
  29. TELEPHONE CONFERENCE HELD ON 3/10/2026. ALL PARTIES APPEARED THROUGH COUNSEL. DISCUSSIONS HAD REGARDING THE STATUS OF SCHEDULING DISCOVERY DEPOSITIONS. ATTORNEYS TO CONTINUE TO CONFER AND AGREE TO DATES FOR TAKING DISCOVERY DEPOSITIONS. PLAINTIFF IS GRANTED LEAVE TO FILE A REPLY BRIEF IN SUPPORT OF HER MOTION TO AMEND THE COMPLAINT UNTIL 3/11/2026. ALL PARTIES AGREED TO ADJUST THE CASE MANAGEMENT SCHEDULE IN ORDER TO COMPLETE OUTSTANDING DISCOVERY: PLAINTIFF'S EXPERT REPORT DUE 4/10/2026. DEFENDANT'S EXPERT REPORT DUE 5/8/2026. PLAINTIFF'S REBUTTAL EXPERT REPORT DUE 5/22/2026. THE PARTIES ARE ORDERED TO ENGAGE IN PRIVATE MEDIATION DURING THE WEEK OF 5/11/2026. THE COURT SCHEDULES A HEARING TO ADDRESS THE DISCOVERY MOTIONS AS FOLLOWS: HEARING SET FOR 04/01/2026 AT 09:00 AM. HEARING TO ADDRESS PLAINTIFF'S PENDING MOTIONS TO COMPEL AND REQUEST FOR SANCTIONS. ALL PARTIES TO APPEAR WITH COUNSEL. NOTICE ISSUED
  30. REPLY BRIEF FILED BY P1 WILLIAM SHANNON SUSAN E PETERSEN 0069741 PLAINTIFFS' REPLY IN SUPPORT OF MOTION FOR LEAVE TO FILE FIRST AMENDED COMPLAINT
  31. NOTICE FILED BY P1 WILLIAM SHANNON ATTORNEY SUSAN E PETERSEN 0069741 PLAINTIFFS' NOTICE OF FILING RETURN OF SERVICE OF SUBPOENA SERVED UPON MATTHEW THOMAS
  32. MOTION FILED FOR PLAINTIFF(S) WILLIAM SHANNON(P1) and JEANNIE SHANNON(P2) SUSAN E PETERSEN 0069741 PLAINTIFFS' MOTION TO COMPEL DISCOVERY FROM DEFENDANT DOMINIQUE COOPER
  33. MOTION FILED FOR P1 WILLIAM SHANNON SUSAN E PETERSEN 0069741 PLAINTIFFS' MOTION TO COMPEL DISCOVERY FROM DEFENDANT TJM EXPRESS, INC.
  34. NOTICE FILED BY P1 WILLIAM SHANNON ATTORNEY SUSAN E PETERSEN 0069741 PLAINTIFFS' NOTICE OF FILING RETURN OF SERVICE OF SUBPOENA SERVED UPON MATTHEW THOMAS
  35. NOTICE FILED BY P1 WILLIAM SHANNON ATTORNEY SUSAN E PETERSEN 0069741 PLAINTIFFS' NOTICE OF FILING RETURN OF SERVICE OF THE SUBPOENA SERVED UPON TOM MCCARTHY
  36. BRIEF IN OPPOSITION FILED BY DEFENDANT(S) FEDERAL EXPRESS CORPORATION(D1) and TJM EXPRESS, INC.(D2) Y TIMOTHY CHAI 0092202 FEDERAL EXPRESS CORPORATION AND TJM EXPRESS, INC.'S RESPONSE IN OPPOSITION TO PLAINTIFF'S RENEWED MOTION TO COMPEL DISCOVERY AND REQUEST FOR SANCTIONS
  37. BRIEF IN OPPOSITION FILED BY DEFENDANT(S) FEDERAL EXPRESS CORPORATION(D1) and TJM EXPRESS, INC.(D2) Y TIMOTHY CHAI 0092202 DEFENDANTS FEDERAL EXPRESS CORPORATION AND TJM EXPRESS, INC.'S RESPONSE IN OPPOSITION TO PLAINTIFFS' MOTION FOR SANCTIONS AND TO COMPED DISCOVERY
  38. BRIEF IN OPPOSITION FILED BY DEFENDANT(S) FEDERAL EXPRESS CORPORATION(D1), TJM EXPRESS, INC.(D2) and DOMINIQUE COOPER(D3) Y TIMOTHY CHAI 0092202 DEFENDANTS' RESPONSE IN OPPOSITION TO PLAINTIFFS' MOTION FOR LEAVE TO FILE AMENDED COMPLAINT
  39. FILED UNDER SEAL EXHIBITS FILED
  40. FILED UNDER SEAL TJM EXPRESS, INC'S ANSWERS & OBJECTIONS TO PLAINTIFFS' FIRST SET OF INTERROGATORIES & REQUEST FOR PRODUCTION OF DOCUMENTS TO FEDERAL EXPRESS CORPORATION. (WITH EXHIBITS) Y TIMOTHY CHAI (0092202)
  41. FILED UNDER SEAL DEFENDANTS' RESPONSE IN OPPOSITION TO PLAINTIFF'S MOTION FOR LEAVE TI FILE AMENDED COMPLAINT . Y TIMOTHY CHAI (0092202)
  42. FILED UNDER SEAL DEFENDANTS' NOTICE OF FILING UNDER SEAL DEFENDANTS' RESPONSE IN OPPOSITION TO PLAINTIFFS' MOTION FOR LEAVE TO FILE AMENDED COMPLAINT
  43. TELEPHONE CONFERENCE HELD ON 2/20/2026. ALL PARTIES APPEARED THROUGH COUNSEL. PLAINTIFF'S COUNSEL ADVISED THAT THERE ARE ONGOING DISCOVERY ISSUES WITH UNPRODUCED AND/OR INCOMPLETE DISCOVERY PROPOUNDED UPON DEFENDANTS. PLAINTIFF TO FILE A MOTION TO COMPEL. NOTICE ISSUED
  44. MOTION FILED FOR PLAINTIFF(S) WILLIAM SHANNON(P1) and JEANNIE SHANNON(P2) SUSAN E PETERSEN 0069741 PLAINTIFFS' RENEWED MOTION TO COMPEL DISCOVERY FROM DEFENDANT FEDERAL EXPRESS CORPORATION AND REQUEST FOR SANCTIONS UNDER CIV. R. 37
  45. MOTION FILED FOR PLAINTIFF(S) WILLIAM SHANNON(P1) and JEANNIE SHANNON(P2) SUSAN E PETERSEN 0069741 PLAINTIFFS' MOTION FOR SANCTIONS AND TO COMPEL DEPOSITIONS
  46. NOTICE FILED BY PLAINTIFF(S) WILLIAM SHANNON(P1) and JEANNIE SHANNON(P2) ATTORNEY SUSAN E PETERSEN 0069741 NOTICE OF FILING EXHIBITS E & F UNDER SEAL
  47. NOTICE FILED BY PLAINTIFF(S) WILLIAM SHANNON(P1) and JEANNIE SHANNON(P2) ATTORNEY SUSAN E PETERSEN 0069741 PLAINTIFFS' NOTICE OF FILING UNDER SEAL EXCERPTS OF PLAINTIFFS' MOTION FOR LEAVE TO FILE FIRST AMENDED COMPLAINT SECTION C-I
  48. MOTION FILED FOR PLAINTIFF(S) WILLIAM SHANNON(P1) and JEANNIE SHANNON(P2) SUSAN E PETERSEN 0069741 PLAINTIFFS' MOTION FOR LEAVE TO FILE FIRST AMENDED COMPLAINT
  49. TELEPHONE CONFERENCE HELD ON 2/11/2026. ALL PARTIES APPEARED THROUGH COUNSEL. DISCUSSIONS HAD REGARDING OUTSTANDING DISCOVERY. PARTIES CONFIRMED THEY HAVE SCHEDULED DEPOSITIONS. PARTIES TO CONFER AND ATTEMPT RESOLUTION OF ALL OTHER DISCOVERY ISSUES. THE COURT SCHEDULES A FOLLOW-UP CONFERENCE CALL AS FOLLOWS: TELEPHONE CONFERENCE SET FOR 02/20/2026 AT 09:00 AM. ATTORNEYS AND ANY PRO SE PARTIES TO CALL INTO THE CONFERENCE LINE AT THE APPROPRIATE TIME: (267)807-9611, ACCESS CODE 397453. NOTICE ISSUED
  50. DEFENDANTS' MOTION FOR PERMISSION TO APPEAR PHV OF BRYSON F. DATT, JR. 02/09/2026, IS GRANTED. NOTICE ISSUED
  51. MOTION FILED FOR DEFENDANT(S) FEDERAL EXPRESS CORPORATION(D1), TJM EXPRESS, INC.(D2) and DOMINIQUE COOPER(D3) Y TIMOTHY CHAI 0092202 MOTION FOR PERMISSION TO APPEAR PHV OF BRYSON F. DATT, JR.
  52. TELEPHONE CONFERENCE HELD ON 2/6/2026. ALL PARTIES APPEARED THROUGH COUNSEL. DISCUSSIONS HAD REGARDING DISCOVERY. DEFENSE COUNSEL ADVISED THAT ALL OUSTANDING DISCOVERY AND/OR CONFIRMATION THAT CERTAIN DOCUMENTS REQUESTED IN DISCOVERY DO NOT EXIST WILL BE PRODUCED BY END OF BUSINESS ON 2/9/2026. COUNSEL TO CONTINUE ATTEMPTS TO SCHEDULE DEPOSITIONS. THE COURT SCHEDULES A TELEPHONE CONFERENCE AS FOLLOWS: TELEPHONE CONFERENCE SET FOR 02/11/2026 AT 02:30 PM. ATTORNEYS AND ANY PRO SE PARTIES TO CALL INTO THE CONFERENCE LINE AT THE APPROPRIATE TIME: (267)807-9611, ACCESS CODE 397453. NOTICE ISSUED
  53. MOTION FOR PERMISSION TO APPEAR PHV OF MICHAEL BETHUNE 02/05/2026, IS GRANTED. NOTICE ISSUED
  54. TELEPHONE CONFERENCE SET FOR 02/06/2026 AT 12:00 PM. ATTORNEYS AND ANY PRO SE PARTIES TO CALL INTO THE CONFERENCE LINE AT THE APPROPRIATE TIME: (267)807-9611, ACCESS CODE 397453. NOTICE ISSUED
  55. MOTION FILED FOR DEFENDANT(S) FEDERAL EXPRESS CORPORATION(D1), TJM EXPRESS, INC.(D2) and DOMINIQUE COOPER(D3) Y TIMOTHY CHAI 0092202 MOTION FOR PERMISSION TO APPEAR PHV OF MICHAEL BETHUNE
  56. PLAINTIFFS' MOTION FOR EXTENSION OF FACT DISCOVERY AND EXPERT DEADLINES 01/16/2026, IS GRANTED. THE COURT EXTENDS THE SCHEDULE AS FOLLOWS: FACT DISCOVERY TO BE COMPLETED BY 2/28/2026. PLAINTIFF'S EXPERT REPORT DEADLINE SET FOR 3/16/2026. DISPOSITIVE MOTION TO BE FILED BY 4/30/2026. RESPONSE AND REPLY DUE PER CIV. R. 6(C). DEFENDANT'S EXPERT REPORT DEADLINE SET FOR 4/30/2026. PLAINTIFF'S REBUTTAL EXPERT REPORT DEADLINE SET FOR 5/30/2026. FINAL PRETRIAL SET FOR 5/4/2026 AND TRIAL SET FOR 6/1/2026 TO REMAIN AS SCHEDULED. NOTICE ISSUED
  57. MOTION FILED FOR P1 WILLIAM SHANNON SUSAN E PETERSEN 0069741 PLAINTIFFS' MOTION FOR EXTENSION OF FACT DISCOVERY AND EXPERT DEADLINES
  58. PROTECTIVE ORDER. O.S.J. NOTICE ISSUED
  59. TELEPHONE CONFERENCE HELD ON 12/3/2025. ALL PARTIES APPEARED THROUGH COUNSEL. DISCUSSIONS HAD REGARDING ANY OUTSTANDING DISCOVERY. COUNSEL ADVISED THAT THE OUTSTANDING DISCOVERY ISSUES ADDRESSED IN PLAINTIFF'S MOTION TO COMPEL HAVE BEEN RESOLVED AND THE MOTION CAN BE MARKED AS MOOT. THE PARTIES HAVE ENTERED INTO A JOINT STIPULATED PROTECTIVE ORDER, WHICH HAS BEEN SUBMITTED TO THE COURT AND WILL BE SIGNED AND ENTERED ON THE DOCKET. NOTICE ISSUED
  60. TELEPHONE CONFERENCE HELD ON 11/12/2025. ALL PARTIES APPEARED THROUGH COUNSEL. COUNSEL ADVISED THAT THEY ARE MAKING PROGRESS FINALIZING DEFENDANT'S PRODUCTION OF DISCOVERY RESPONSES AND THE STIPULATED PROTECTIVE ORDER. PARTIES TO FILE EITHER A JOINT MOTION FOR STIPULATED PROTECTIVE ORDER OR CONTESTED MOTIONS FOR STIPULATED PROTECTIVE ORDER BY 11/17/2025. THE COURT SCHEDULES A FOLLOW-UP TELEPHONE CONFERENCE AS FOLLOWS: TELEPHONE CONFERENCE SET FOR 12/03/2025 AT 02:00 PM. ATTORNEYS AND ANY PRO SE PARTIES TO CALL INTO THE CONFERENCE LINE AT THE APPROPRIATE TIME: (267)807-9611, ACCESS CODE 397453. NOTICE ISSUED
  61. TELEPHONE CONFERENCE HELD ON 11/5/2025. ALL PARTIES APPEARED THROUGH COUNSEL. DISCUSSIONS HAD REGARDING PLAINTIFF'S MOTION TO COMPEL, FILED 10/8/2025, AND DEFENDANT'S BRIEF IN OPPOSITION, FILED 10/22/2025. COUNSEL ADVISED THAT THE PARTIES ARE WORKING TO RESOLVE ANY OUTSTANDING DISCOVERY ISSUES AND ARE NEGOTIATING THE TERMS OF A STIPULATED PROTECTIVE ORDER. DEFENDANT TO USE BEST EFFORTS TO SEND PLAINTIFF'S COUNSEL A RED-LINED VERSION OF THE PROPOSED PROTECTIVE ORDER AND THE VIDEO FOOTAGE OF THE COLLISION AT ISSUE BY 11/7/2025. THE COURT SCHEDULES A FOLLOW-UP STATUS CONFERENCE AS FOLLOWS: TELEPHONE CONFERENCE SET FOR 11/12/2025 AT 03:30 PM. ATTORNEYS AND ANY PRO SE PARTIES TO CALL INTO THE CONFERENCE LINE AT THE APPROPRIATE TIME: (267)807-9611, ACCESS CODE 397453. NOTICE ISSUED
  62. TELEPHONE CONFERENCE SET FOR 11/05/2025 AT 02:30 PM. ATTORNEYS AND ANY PRO SE PARTIES TO CALL INTO THE CONFERENCE LINE AT THE APPROPRIATE TIME: (267)807-9611, ACCESS CODE 397453. NOTICE ISSUED
  63. GENERAL PLEADING FILED BY D1 FEDERAL EXPRESS CORPORATION ATTORNEY Y TIMOTHY CHAI 0092202 DEFENDANT FEDERAL EXPRESS CORPORATION'S RESPONSE IN OPPOSITION TO PLAINTIFF'S MOTION TO COMPEL
  64. MOTION FILED FOR P1 WILLIAM SHANNON SUSAN E PETERSEN 0069741 PLAINTIFFS' MOTION TO COMPEL
  65. NOTICE FILED BY P1 WILLIAM SHANNON ATTORNEY SUSAN E PETERSEN 0069741 PLAINTIFFS' NOTICE OF SERVICE OF INITIAL DISCLOSURES
  66. CMC BY PHONE HELD ON 06/18/2025. ALL PARTIES APPEARED THROUGH COUNSEL AND AGREED TO THE FOLLOWING CASE MANAGEMENT SCHEDULE: FACT DISCOVERY TO BE COMPLETED BY 01/15/2026. PLAINTIFF'S EXPERT REPORT DUE 2/15/2026. DEFENDANT'S EXPERT REPORT DUE 3/31/2026. PLAINTIFF'S REBUTTAL EXPERT REPORT DUE 4/30/2026. THE PARTIES ADVISED THAT THEY MAY SEEK PRIVATE MEDIATION. PARTIES TO ENGAGE IN PRIVATE MEDIATION BY 4/30/2026. DISPOSITIVE MOTION TO BE FILED BY 03/16/2026. RESPONSE AND REPLY DUE PER CIV. R. 6(C). FINAL PRETRIAL SET FOR 05/04/2026 AT 10:00 AM. ALL PARTIES WITH SETTLEMENT AUTHORITY TO APPEAR IN PERSON. ALL PARTIES TO FILE FINAL PRETRIAL STATEMENTS AT LEAST 7 DAYS PRIOR TO THE FINAL PRETRIAL. JURY TRIAL SET FOR 06/01/2026 AT 10:00 AM. COURTESY PAPER COPIES OF ALL TRIAL FILINGS AND PRETRIAL MOTIONS SHALL BE DELIVERED TO COURTROOM 22-D ON THE DAY OF FILING. ALL MOTIONS IN LIMINE SHALL BE FILED NO LATER THAN FOURTEEN (14) DAYS PRIOR TO TRIAL. RESPONSES TO MOTIONS IN LIMINE DUE SEVEN (7) DAYS PRIOR TO TRIAL. THE FOLLOWING TRIAL DOCUMENTS SHALL BE FILED NO LATER THAN SEVEN (7) DAYS PRIOR TO TRIAL. 1. WITNESS LISTS 2. LIST OF PROPOSED EXHIBITS 3. LIST OF STIPULATIONS TO BE PRESENTED 4. TRIAL BRIEFS 5. JOINT PROPOSED JURY INSTRUCTIONS, INTERROGATORIES, AND VERDICT FORMS 6. JOINT BRIEF STATEMENT OF THE CASE TO BE READ TO THE JURY 7. ALL EXPERT REPORTS 8. DEPOSITION TRANSCRIPTS OF EXPERT WITNESSES 9. PARTIES TO SUBMIT OBJECTION LOGS FOR OBJECTIONS TO VIDEOTAPE AND DEPOSITION TESTIMONY WITH A COPY OF THE TRANSCRIPT AND, IF APPLICABLE, A COPY OF THE VIDEOTAPE. THE COURT ADVISES THE PARTIES TO ENDEAVOR TO RESOLVE ALL BUT THE MOST CRUCIAL OBJECTIONS. THE COURT WILL ONLY ISSUE RULINGS ON A VERY LIMITED NUMBER OF OBJECTIONS. FAILURE TO COMPLY WITH THE COURT'S PRE-TRIAL ORDER MAY RESULT IN SANCTIONS INCLUDING BUT NOT LIMITED TO, PROHIBITING THE INTRODUCTION OF EVIDENCE AT TRIAL, LIMITING OR DISMISSAL OF CLAIMS AND/OR DEFENSES, GRANTING OF COSTS AND/OR ATTORNEYS FEES AND SUCH OTHER RELIEF AS THE COURT DEEMS APPROPRIATE. NOTICE ISSUED
  67. GENERAL PLEADING FILED BY P1 WILLIAM SHANNON ATTORNEY SUSAN E PETERSEN 0069741 JOINT REPORT PURSUANT TO OHIO CIVIL RULE 26(F)
  68. ANSWER FILED BY D2 TJM EXPRESS, INC. ATTORNEY Y TIMOTHY CHAI 0092202 ANSWER OF DEFENDANT TJM EXPRESS INC.
  69. ANSWER FILED BY D3 DOMINIQUE COOPER ATTORNEY Y TIMOTHY CHAI 0092202 ANSWER OF DEFENDANT DOMINIQUE COOPER
  70. SUMS COMPLAINT(57098400) SENT BY REGULAR MAIL SERVICE. TO: DOMINIQUE COOPER 4241 BERKSHIRE DRIVE SE APT. 7 WARREN, OH 44484 ANSWER DATE: 06/25/2025
  71. SUMMONS E-FILE COPY COST
  72. WRIT FEE
  73. SUMS COMPLAINT(57085803) SENT BY REGULAR MAIL SERVICE. TO: TJM EXPRESS, INC. 2833 CASTLE VIEW NW UNIONTOWN, OH 44685 ANSWER DATE: 06/24/2025
  74. SUMMONS E-FILE COPY COST
  75. WRIT FEE
  76. REQUEST FOR SERVICE FILED INSTRUCTIONS FOR SERVICE
  77. REQUEST FOR SERVICE FILED INSTRUCTIONS FOR SERVICE
  78. CMC BY PHONE SET FOR 06/18/2025 AT 09:45 AM ATTORNEYS AND ANY PRO SE PARTIES TO CALL INTO THE CONFERENCE LINE AT THE APPROPRIATE TIME: (267)807-9611, ACCESS CODE 397453. NOTICE ISSUED
  79. ANSWER FILED BY D1 FEDERAL EXPRESS CORPORATION ATTORNEY Y TIMOTHY CHAI 0092202 ANSWER OF DEFENDANT FEDERAL EXPRESS CORPORATION
  80. CERTIFIED MAIL NUMBER 56370383 ADDRESSED TO FEDERAL EXPRESS CORPORATION(D1) NOT RETURNED BY THE U.S. POSTAL SERVICE AFTER 60 DAYS. NOTICE MAILED TO PLAINTIFF(S) ATTORNEY.
  81. CERTIFIED MAIL RECEIPT NO. 56370384 RETURNED 4/8/2025 FAILURE OF SERVICE ON DEFENDANT TJM EXPRESS, INC. - UNCLAIMED NOTICE MAILED TO PLAINTIFF(S) ATTORNEY
  82. CERTIFIED MAIL RECEIPT NO. 56370385 RETURNED 4/3/2025 FAILURE OF SERVICE ON DEFENDANT COOPER/DOMINIQUE/ - UNCLAIMED NOTICE MAILED TO PLAINTIFF(S) ATTORNEY
  83. SUMS COMPLAINT(56370385) SENT BY CERTIFIED MAIL. TO: DOMINIQUE COOPER 4241 BERKSHIRE DRIVE SE APT. 7 WARREN, OH 44484
  84. SUMS COMPLAINT(56370384) SENT BY CERTIFIED MAIL. TO: TJM EXPRESS, INC. 2833 CASTLE VIEW NW UNIONTOWN, OH 44685
  85. SUMS COMPLAINT(56370383) SENT BY CERTIFIED MAIL. TO: FEDERAL EXPRESS CORPORATION 4400 EASTON COMMONS WAY SUITE 125 COLUMBUS, OH 43219
  86. SUMMONS E-FILE COPY COST
  87. SUMMONS E-FILE COPY COST
  88. SUMMONS E-FILE COPY COST
  89. WRIT FEE
  90. WRIT FEE
  91. WRIT FEE
  92. JUDGE SHANNON M GALLAGHER ASSIGNED (RANDOM)
  93. LEGAL RESEARCH
  94. LEGAL NEWS
  95. LEGAL AID
  96. COURT SPECIAL PROJECTS FUND
  97. COMPUTER FEE
  98. CLERK'S FEE
  99. DEPOSIT AMOUNT PAID SUSAN E PETERSEN

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