Trade Well International v. United Central Bank

Filing 138

Transmission of Notice of Appeal, Docketing Statement, Opinion and Order, and Docket Sheet to Seventh Circuit Court of Appeals re: 136 Notice of Appeal, (Attachments: # 1 Docketing Statement, # 2 Opinion and Order, # 3 Docket Sheet) (lak)

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APPEAL, CLOSED, DIVERSITY, TCB,

U.S. District Court
Western District of Wisconsin (Madison)
CIVIL DOCKET FOR CASE #: 3:12-cv-00701-jdp

Trade Well International v. United Central Bank
Assigned to: District Judge James D. Peterson
Referred to: Magistrate Judge Stephen L. Crocker
Case in other court: USCA for the 7th Circuit, 14-01907
Cause: 28:1332 Diversity-Property Damage

Date Filed: 09/26/2012
Date Terminated: 10/27/2014
Jury Demand: Plaintiff
Nature of Suit: 380 Personal Property:
Other
Jurisdiction: Diversity

Plaintiff
Trade Well International
Muhammad Tahir, Managing Member
Suite no. 02, Bloc no. 06
F-8/3
Islamabad, Pakistan
a Pakistan Corporation

represented by Maurice J. Salem
7156 W. 127th Street, B-149
Palos Heights, IL 60463
708-277-4775
Fax: [phone]
Email: [e-mail]
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Plaintiff
Dells Lodging Operator Inc.
Involuntary Plaintiff

represented by Maurice J. Salem
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Plaintiff
Dells Estate LLC
Involuntary Plaintiff

represented by Maurice J. Salem
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

V.
Defendant
United Central Bank
a Texas Corporation

represented by Robert A. Pasch
Murphy Desmond SC
33 East Main Street
Suite 500
PO Box 2038
Madison, WI 53701-2038
608-257-7181

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Fax: [phone]
Email: [e-mail]
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Brian Patrick Thill
P.O. Box 2038
Madison, WI 53701-2038
608-268-5566
Fax: [phone]
Email: [e-mail]
ATTORNEY TO BE NOTICED
Counter Defendant
Trade Well International
a Pakistan Corporation

represented by Maurice J. Salem
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Interested Party
Maurice James Salem

represented by Maurice J. Salem
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Counter Claimant
United Central Bank
a Texas Corporation

represented by Robert A. Pasch
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Brian Patrick Thill
(See above for address)
ATTORNEY TO BE NOTICED

Date Filed

#

Docket Text

09/26/2012

1 Motion to Admit Maurice J. Salem Pro Hac Vice. ( Pro Hac Vice fee $ 50 receipt
number 0758-1054997.) by Plaintiff Trade Well International. (Attachments:
# 1 Proposed Order) (Salem, Maurice) (Entered: 09/26/2012)

09/26/2012

2 COMPLAINT against United Central Bank (filing fee $350 receipt number
0758-1055021), filed by Trade Well International. (Attachments:
# 1 Exhibit A - Lease Agreement,
# 2 Exhibit B - Property Description,
# 3 Exhibit C - Notice of Demand for Personal Property,
# 4 JS-44 Civil Cover Sheet,

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# 5 Summons) (Salem, Maurice) Modified on 9/27/2012 (jaf). Modified on
9/27/2012 (llj). (Entered: 09/26/2012)
09/27/2012

Case randomly assigned to District Judge William M. Conley and Magistrate Judge
Stephen L. Crocker. (llj) (Entered: 09/27/2012)

09/27/2012

Standard attachments for Judge William M. Conley required to be served on all
parties with summons or waiver of service: NORTC, Briefing Guidelines, Corporate
Disclosure Statement. (llj) (Entered: 09/27/2012)

09/27/2012

3 ** TEXT ONLY ORDER **
ORDER granting 1 Motion to Admit Maurice Salem Pro Hac Vice. Signed by
Magistrate Judge Peter A. Oppeneer on 9/27/2012. (llj) (Entered: 09/27/2012)

09/27/2012

4 Summons Issued as to United Central Bank. (llj) (Entered: 09/27/2012)

10/23/2012

5 Notice of Appearance filed by Brian Patrick Thill for Defendant United Central
Bank (Thill, Brian) (Entered: 10/23/2012)

10/23/2012

6 Corporate Disclosure Statement by Defendant United Central Bank (Thill, Brian)
(Entered: 10/23/2012)

11/14/2012

Set Telephone Pretrial or Status Conference: Telephone Pretrial Conference set for
12/14/2012 at 02:00 PM before Magistrate Judge Stephen L. Crocker. Counsel for
Plaintiff responsible for setting up the call to chambers at [phone]. [Standing
Order Governing Preliminary Pretrial Conference attached] (llj) (Entered:
11/14/2012)

11/26/2012

7 MOTION TO DISMISS for Lack of Jurisdiction and Failure to Join Necessary
Parties by Defendant United Central Bank. Brief in Opposition due 12/17/2012.
Brief in Reply due 12/27/2012. (Thill, Brian) (Entered: 11/26/2012)

11/26/2012

8 Brief in Support of 7 Motion to Dismiss/Lack of Jurisdiction by Defendant United
Central Bank (Thill, Brian) (Entered: 11/26/2012)

11/26/2012

9 Affidavit of Brian P. Thilll filed by Defendant United Central Bank re: 7 Motion to
Dismiss/Lack of Jurisdiction (Attachments:
# 1 State Court DLO Answer,
# 2 DFI DLO Report,
# 3 DFI Dells Estate Report) (Thill, Brian) Modified on 11/27/2012 (llj). (Entered:
11/26/2012)

11/26/2012

10 Notice of filing by Defendant United Central Bank re 7 MOTION TO DISMISS for
Lack of Jurisdiction and Failure to Join Necessary Parties . (Thill, Brian) Modified
on 11/27/2012 (llj). (Entered: 11/26/2012)

12/12/2012

11 Joint Report of Rule 26(f) Planning Meeting (Salem, Maurice) (Entered:
12/12/2012)

12/17/2012

12 Pretrial Conference Order - Dispositive Motions due 8/30/2013. Settlement Letters
due 12/20/2013. Motions in Limine due 1/3/2014. Response to Motion due
1/17/2014. Final Pretrial Conference set for 1/28/2014 at 04:00 PM. Jury Selection
and Trial set for 2/3/2014 at 09:00 AM. Signed by Magistrate Judge Stephen L.

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Crocker on 12/17/2012. (llj) (Entered: 12/17/2012)
12/17/2012

Set/Reset Briefing Deadlines as to 7 MOTION TO DISMISS for Lack of
Jurisdiction and Failure to Join Necessary Parties. Brief in Opposition due
12/21/2012. Brief in Reply due 1/4/2013. (llj) (Entered: 12/17/2012)

12/18/2012

Minute Entry for proceedings held before Magistrate Judge Stephen L. Crocker:
Telephone Preliminary Pretrial Conference held on 12/14/2012 [:15] (cak) (Entered:
12/18/2012)

12/21/2012

13 Brief in Opposition by Plaintiff Trade Well International re: 7 Motion to
Dismiss/Lack of Jurisdiction filed by United Central Bank (Salem, Maurice)
(Entered: 12/21/2012)

01/04/2013

14 Brief in Reply by Defendant United Central Bank in Support of 7 Motion to
Dismiss/Lack of Jurisdiction (Thill, Brian) (Entered: 01/04/2013)

01/04/2013

15 Disregard. See docket entry 16 . Requested attorney refile with exhibits as
individual attachments on 1/7/2013 (jaf). Modified on 1/8/2013 (jaf). (Entered:
01/04/2013)

01/07/2013

16 Second Affidavit of Brian P. Thill filed by Defendant United Central Bank re: 7
Motion to Dismiss/Lack of Jurisdiction (Attachments:
# 1 Exhibit 1: Dells Estate LLC Case Search,
# 2 Exhibit 2: State Case Overview,
# 3 Exhibit 3: Dells Estate LLC DFI Report,
# 4 Exhibit 4: DLO Claim,
# 5 Exhibit 5: Trade Well Correspondence 1,
# 6 Exhibit 6: Trade Well Correspondence 2) (Thill, Brian) Modified attachment
descriptions on 1/8/2013 (llj). (Entered: 01/07/2013)

09/30/2013

17 ORDER denying 7 Motion to Dismiss for Lack of Jurisdiction. Signed by District
Judge William M. Conley on 9/30/2013. (voc) (Entered: 09/30/2013)

10/14/2013

18 Corporate Disclosure Statement by Plaintiff Trade Well International (Salem,
Maurice) (Entered: 10/14/2013)

10/14/2013

19 Motion for Extension of Time to file amended complaint, Motion to Compel
Defendant to permit Plaintiff's agent to inspect the subject property by Plaintiff
Trade Well International. Motions referred to Magistrate Judge Stephen L. Crocker.
Response due 10/21/2013. (Attachments:
# 1 Attorney's Declaration - See also 20 ,
# 2 Proposed Order) (Salem, Maurice) Requested attorney refile declaration as
individual docket entry on 10/15/2013 (jaf). Modified on 10/16/2013 (jaf). (Entered:
10/14/2013)

10/15/2013

20 Declaration of Plaintiff's Attorney Maurice J. Salem filed by Plaintiff Trade Well
International re: 19 MOTION for Extension of Time, Motion to Compel,, (Salem,
Maurice) (Entered: 10/15/2013)

10/16/2013

21 ORDER granting 19 Motion for Extension of Time ; Granting 19 Motion to
Compel. A telephone conference will be held on 11/26/2013 at 1:30 PM, before

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Magistrate Judge Stephen L. Crocker. Signed by District Judge William M. Conley
on 10/15/2013. (voc) (Entered: 10/16/2013)
10/16/2013

Set Hearing: Telephone Scheduling Conference set for 11/26/2013 at 01:30 PM
before Magistrate Judge Stephen L. Crocker. Counsel for Plaintiff responsible for
setting up the call to chambers at [phone]. (voc) (Entered: 10/16/2013)

10/31/2013

22 Motion to Stay the sale of the subject hotel, with Plaintiff's equipment in it, by
Plaintiff Trade Well International. Response due 11/7/2013. (Attachments:
# 1 Paracha Affidavit - See also 24 ,
# 2 Salem Declaration - See also 25 ,
# 3 Proposed Order) (Salem, Maurice) Requested attorney refile declaration and
affidavit as individual docket entries on 11/1/2013 (jaf). Modified on 11/5/2013
(jaf). (Entered: 10/31/2013)

11/01/2013

23 Brief in Support of 22 Motion to Stay, by Plaintiff Trade Well International
(Attachments:
# 1 Exhibit A - Paracha Affidavit - See also 24 ,
# 2 Exhibit B - Salem Declaration - See also 25 ,
# 3 Proposed Order) (Salem, Maurice) Requested attorney file supporting
documents as individual docket entries on 11/4/2013 (jaf). Modified on 11/5/2013
(jaf). (Entered: 11/01/2013)

11/04/2013

24 Affidavit of Umar F. Paracha filed by Plaintiff Trade Well International re: 22
Motion to Stay, (Salem, Maurice) (Entered: 11/04/2013)

11/04/2013

25 Declaration of Maurice J. Salem filed by Plaintiff Trade Well International re: 22
Motion to Stay, (Salem, Maurice) (Entered: 11/04/2013)

11/04/2013

26 Brief in Opposition by Defendant United Central Bank re: 22 Motion to Stay the
sale of the subject hotel, with Plaintiff's equipment in it, filed by Trade Well
International (Thill, Brian) Modified on 11/5/2013 (jaf). (Entered: 11/04/2013)

11/04/2013

27 Motion to Compel Plaintiff to Remove Alleged Personal Property from Defendant's
Real Property by Defendant United Central Bank. Motions referred to Magistrate
Judge Stephen L. Crocker. Response due 11/12/2013. (Thill, Brian) (Entered:
11/04/2013)

11/04/2013

28 Brief in Support of 27 Motion to Compel by Defendant United Central Bank (Thill,
Brian) (Entered: 11/04/2013)

11/04/2013

29 Affidavit of Brian P. Thill filed by Defendant United Central Bank re: 27 Motion to
Compel (Attachments:
# 1 Exhibit State Court Case Docket) (Thill, Brian) Modified on 11/5/2013 (jaf).
(Entered: 11/04/2013)

11/07/2013

30 Brief in Opposition by Plaintiff Trade Well International re: 27 Motion to Compel
filed by United Central Bank (Salem, Maurice) (Entered: 11/07/2013)

11/07/2013

31 Declaration of Maurice J. Salem filed by Plaintiff Trade Well International in
Response to Defendant's Motion to Compel re: 27 Motion to Compel (Salem,
Maurice) (Entered: 11/07/2013)

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32 AMENDED COMPLAINT against United Central Bank, filed by Trade Well
International, Dells Lodging Operator Inc., Dells Estate LLC. (Attachments:
# 1 Exhibit A - Lease Agreement with Involuntary Plaintiff Dells Estate LLC,
# 2 Exhibit B - Lease for Hotel Equipment,
# 3 Exhibit C - Notice for Demand of Personal Property,
# 4 Exhibit D - Trade Fixtures Addendum,
# 5 Exhibit E - Corporate Dissolution Paper for Dells Estate LLC) (Salem, Maurice)
Modified on 11/18/2013 (jaf). (Entered: 11/15/2013)

11/22/2013

Set Deadlines as to 22 Motion to Stay the sale of the subject hotel, with Plaintiff's
equipment in it,, 27 Motion to Compel Plaintiff to Remove Alleged Personal
Property from Defendant's Real Property. Motion Hearing set for 12/4/2013 at
09:00 AM. (rep) (Entered: 11/22/2013)

11/25/2013

Reset Hearings: Telephone Scheduling Conference rescheduled from 11/26/2013 to
12/13/2013 at 02:30 PM before Magistrate Judge Stephen L. Crocker. Counsel for
Plaintiff responsible for setting up the call to chambers at [phone]. (voc)
(Entered: 11/25/2013)

11/26/2013

33 Request for Issuance of Summons by Plaintiff Trade Well International. (Salem,
Maurice) (Entered: 11/26/2013)

11/27/2013

34 Summons Issued as to Dells Lodging Operator Inc. (voc) (Entered: 11/27/2013)

12/03/2013

35 Summons Returned Executed. Dells Lodging Operator Inc. served on 12/2/2013,
answer due 12/23/2013. (Attachments:
# 1 Signature Page) (Salem, Maurice) Modified on 12/4/2013 (jaf). (Entered:
12/03/2013)

12/04/2013

36 ORDER granting in part and denying in part 27 Motion to Compel. ; granting in part
and denying in part 22 Motion to Stay. Signed by District Judge William M. Conley
on 12/4/2013. (voc) (Entered: 12/04/2013)

12/06/2013

37 Request for Issuance of Summons by Plaintiff Trade Well International. (Salem,
Maurice) (Entered: 12/06/2013)

12/06/2013

38 ANSWER to Amended Complaint by Defendant United Central Bank. (Thill, Brian)
(Entered: 12/06/2013)

12/09/2013

39 Summons Issued as to Dells Estate LLC. (voc) (Entered: 12/09/2013)

12/09/2013

40 Minute Entry for proceedings held before District Judge William M. Conley: Motion
Hearing held on 12/4/2013 re: 22 Motion to Stay, 27 Motion to Compel. Plaintiff to
remove personal property (non-fixtures) within 30 days. [:25] (Court Reporter CS)
(arw) (Entered: 12/09/2013)

12/10/2013

41 Summons Returned Executed. Dells Estate LLC served on 12/10/2013, answer due
12/31/2013. (Salem, Maurice) (Entered: 12/10/2013)

12/13/2013

42 AMENDED Scheduling Order: Dispositive Motions due 6/20/2014. Settlement
Letters due 10/24/2014. Motions in Limine due 11/7/2014. Response to Motion due
11/21/2014. Final Pretrial Conference set for 12/2/2014 at 04:00 PM. Jury Selection
and Trial set for 12/8/2014 at 09:00 AM. Signed by Magistrate Judge Stephen L.

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Crocker on 12/17/2013. (voc) (Entered: 12/13/2013)
12/23/2013

43 Motion for Extension of Time to move all damaged equipment, Motion to Compel
Defendant to pay for moving and storing all damaged equipment by Plaintiff Trade
Well International. Motions referred to Magistrate Judge Stephen L. Crocker.
Response due 12/30/2013. (Attachments:
# 1 Proposed Order) (Salem, Maurice) (Entered: 12/23/2013)

12/23/2013

44 Disregard. See docket entry 45 . Requested attorney refile with exhibits attached
separately and named on 12/26/2013 (jaf). Modified on 12/27/2013 (jaf). (Entered:
12/23/2013)

12/26/2013

45 Declaration of Attorney for Plaintiff, Maurice J. Salem filed by Plaintiff Trade Well
International re: 43 MOTION for Extension of Time,, Motion to Compel,
(Attachments:
# 1 Exhibit A, Allied Van Lines email,
# 2 Exhibit B, Reynolds Transfer email,
# 3 Exhibit C, C. Coakley Relocation email) (Salem, Maurice) (Entered:
12/26/2013)

12/27/2013

46 Rule 26 Initial Disclosure Report by Defendant United Central Bank (Thill, Brian)
(Entered: 12/27/2013)

12/30/2013

47 Rule 26 Initial Disclosure Report by Plaintiff Trade Well International (Salem,
Maurice) (Entered: 12/30/2013)

12/30/2013

48 Brief in Opposition by Defendant United Central Bank re: 43 MOTION for
Extension of Time, Motion to Compel,, filed by Trade Well International (Thill,
Brian) (Entered: 12/30/2013)

01/03/2014

49 ORDER granting in part and denying in part 43 Motion for Extension of Time to
move all damaged equipment and to compel defendant to pay for moving and
storing all damaged equipment. Signed by District Judge William M. Conley on
1/3/14. (krj) (Entered: 01/03/2014)

02/13/2014

50 Motion for Entry of Default as to Dells Estate LLC, Dells Lodging Operator Inc. by
Plaintiff United Central Bank. Motions referred to Magistrate Judge Stephen L.
Crocker. (Thill, Brian) Modified on 2/14/2014 (jaf). (Entered: 02/13/2014)

02/13/2014

51 Affidavit of Brian P. Thill filed by Defendant United Central Bank re: 50 Motion for
Entry of Default (Thill, Brian) (Entered: 02/13/2014)

02/13/2014

52 Proposed Entry of Default to 50 Motion for Entry of Default filed by United Central
(Thill, Brian) Modified on 2/14/2014 (jaf). (Entered: 02/13/2014)

02/13/2014

53 Certificate of Service by Defendant United Central Bank as to 51 Affidavit, 52
Exhibit, 50 Motion for Entry of Default as to Dells Estate LLC, Dells Lodging
Operator Inc.. (Thill, Brian) (Entered: 02/13/2014)

02/18/2014

54 ORDER denying 50 Motion for Entry of Default as to involuntary plaintiffs Dells
Lodging Operator, Inc. and Dells Estate LLC. Signed by Peter A. Oppeneer, Clerk
of Court on 2/18/2014. (voc) (Entered: 02/18/2014)

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03/11/2014

55 Motion to Compel the preservation of evidence by Plaintiff Trade Well International.
Motions referred to Magistrate Judge Stephen L. Crocker. Response due 3/18/2014.
(Attachments:
# 1 Proposed Order) (Salem, Maurice) (Entered: 03/11/2014)

03/14/2014

56 Motion to Strike Notice of Lien and for Further Relief by Defendant United Central
Bank. Response due 3/21/2014. (Thill, Brian) (Entered: 03/14/2014)

03/14/2014

57 Fifth Affidavit of Brian P. Thill filed by Defendant United Central Bank re: 56
Motion to Strike (Attachments:
# 1 Exhibit Notice of Lien,
# 2 Exhibit Attorney Search) (Thill, Brian) (Entered: 03/14/2014)

03/14/2014

58 Motion to Shorten Time re 56 Motion to Strike Notice of Lien and for Further Relief
by Defendant United Central Bank. Response due 3/21/2014. (Thill, Brian)
(Entered: 03/14/2014)

03/14/2014

59 ** TEXT ONLY ORDER **
The court is in receipt of defendant's motions to strike notice of lien and for further
relief (dkt. #56) and to shorten time (dkt. #58). Pursuant to a status conference held
this afternoon, the court will grant defendant's motion to shorten time; plaintiff's
response to the motion to strike is due on Monday, March 17; defendant shall have
until end of the day on Thursday, March 20 to file a reply, if any. Signed by District
Judge William M. Conley on 03/14/2014. (mfh) (Entered: 03/14/2014)

03/14/2014

Minute Entry for proceedings held before District Judge William M. Conley:
Telephone Conference held on 3/14/2014 [:15] (mfh) (Entered: 03/14/2014)

03/17/2014

60 Brief in Opposition by Defendant United Central Bank re: 55 Motion to Compel
filed by Trade Well International (Thill, Brian) (Entered: 03/17/2014)

03/18/2014

61 Declaration of Maurice J. Salem filed by Plaintiff Trade Well International in
Response to Defendant's Motion to Strike Notice of Lien re: 56 Motion to Strike
(Salem, Maurice) (Entered: 03/18/2014)

03/18/2014

62 Exhibit to 61 Declaration filed by Trade Well International Exhibit A, Los Angeles
Times Article (Salem, Maurice) (Entered: 03/18/2014)

03/18/2014

63 Exhibit to 61 Declaration filed by Trade Well International Exhibit B, UCB Assistant
Vice President card (Salem, Maurice) (Entered: 03/18/2014)

03/18/2014

64 Exhibit to 61 Declaration filed by Trade Well International Exhibit C, 2008
Purchase Price of Hotel (Salem, Maurice) (Entered: 03/18/2014)

03/18/2014

65 Exhibit to 61 Declaration filed by Trade Well International Exhibit D, Offer to Buy
Plaintiff's Property (Salem, Maurice) (Entered: 03/18/2014)

03/18/2014

66 Exhibit to 61 Declaration filed by Trade Well International Exhibit E, signed
contract to purchase hotel (Salem, Maurice) (Entered: 03/18/2014)

03/18/2014

67 Exhibit to 61 Declaration filed by Trade Well International Exhibit F, email showing
buyer still interested (Salem, Maurice) (Entered: 03/18/2014)

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03/20/2014

68 Motion to Strike 61 Declaration (Inadmissible Portions Only) by Defendant United
Central Bank. Response due 3/27/2014. (Thill, Brian) (Entered: 03/20/2014)

03/20/2014

69 Brief in Reply by Defendant United Central Bank in Support of 68 Motion to Strike,
56 Motion to Strike (Thill, Brian) (Entered: 03/20/2014)

03/25/2014

70 Brief in Opposition by Plaintiff Trade Well International re: 68 Motion to Strike
filed by United Central Bank (Salem, Maurice) (Entered: 03/25/2014)

04/04/2014

71 ORDER denying 55 Motion to Compel preservation of evidence; granting in part
and denying in part 56 Motion to Strike notice of lien and for further relief; granting
68 Motion to Strike inadmissible portions of declaration of Maurice J. Salem.
Attorney Salem held in contempt of court and ordered to pay $500 to clerk of court
and defendant's attorneys' fees incurred by filing lien; clerk of court directed to
forward order to enforcement authorities responsible for practice of law in states of
Wisconsin and New York. Signed by District Judge William M. Conley on 4/4/14.
(krj) (Entered: 04/04/2014)

04/08/2014

72 Motion for Reconsideration of this Court's April 4, 2014, Order (dkt. # 71 ) by
Plaintiff Trade Well International. Response due 4/15/2014. (Salem, Maurice)
Modified on 4/9/2014 (voc). (Entered: 04/08/2014)

04/08/2014

73 Brief in Support of 72 Motion for Reconsideration this Court's April 4, 2014, Order
(dkt. 71) by Plaintiff Trade Well International (Attachments:
# 1 Exhibit A, Plaintiff's expert report,
# 2 Exhibit B, Defendant's expert report,
# 3 Proposed Order) (Salem, Maurice) (Entered: 04/08/2014)

04/11/2014

74 Motion for Leave to File an appearance and for a two week extension to post bond
by Plaintiff Trade Well International. (Attachments:
# 1 Notice of Withdrawal of Lien) (Salem, Maurice) (Entered: 04/11/2014)

04/22/2014

75 ORDER denying 72 Motion for Reconsideration of this Court's April 4, 2014, Order
by Plaintiff Trade Well International. Denying as moot 74 Motion for Leave to File
an appearance and for a two week extension to post bond by Plaintiff Trade Well
International. Attorney Maurice J. Salem is denied admission in this court both now
and for the next three years, and the clerk is directed to forward his admission fee to
defendant's counsel as credit against his previous $500 sanction entered by this
court. Signed by District Judge William M. Conley on 4/22/2014. (voc) (Entered:
04/22/2014)

04/23/2014

76 NOTICE OF APPEAL by Plaintiff Trade Well International as to 71 Order on
Motion to Compel, Order on Motion to Strike, 75 Order on Motion for
Reconsideration, Order on Motion for Leave to File. Filing fee of $505, receipt
number 0758-1337104 paid. No Docketing Statement filed. (Salem, Maurice)
(Entered: 04/23/2014)

04/24/2014

77 Appeal Information Packet. (voc) (Entered: 04/24/2014)

04/24/2014

78 Transmission of Notice of Appeal, Appeal Information Sheet, Order #75, Order #74,
Order #72 and Docket Sheet to Seventh Circuit Court of Appeals re 76 Notice of
Appeal, (Attachments:

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# 1 Appeal Information Sheet,
# 2 Order #75,
# 3 Order #74,
# 4 Order #72,
# 5 Docket Sheet) (voc) (Entered: 04/24/2014)
04/24/2014

79 USCA Case Number 14-1907 for 76 Notice of Appeal, filed by Trade Well
International. (voc) (Entered: 04/24/2014)

05/21/2014

80 ORDER from USCA granting motion for voluntary dismissal of appellant Trade
Well International (Attachments:
# 1 Notice of Issuance of Mandate) (voc) (Entered: 05/21/2014)

05/28/2014

81 Motion to Supplement Appeal Record by Interested Party Maurice James Salem.
(Attachments:
# 1 Exhibits A - D - Record to be Added,
# 2 Exhibit E - CA Scheduling Order) (Salem, Maurice) Modified on 5/29/2014:
Requested attorney re-file with exhibits separated. (lak) (Entered: 05/28/2014)

05/28/2014

Set Briefing Deadlines as to 81 Motion to Supplement Appeal Record . Brief in
Opposition due 6/4/2014. (voc) (Entered: 05/28/2014)

06/04/2014

82 Brief in Opposition by Defendant United Central Bank re: 81 Motion to Supplement
Appeal Record, filed by Maurice James Salem. (Thill, Brian) (Entered: 06/04/2014)

06/04/2014

83 COUNTERCLAIM against Trade Well International, filed by United Central Bank.
(Thill, Brian) Modified on 6/5/2014. (lak) (Entered: 06/04/2014)

06/04/2014

84 Motion to Declare Notice of Lien Void ab Initio by Defendant United Central Bank.
Response due 6/11/2014. (Thill, Brian) (Entered: 06/04/2014)

06/04/2014

85 Brief in Support of 84 Motion to Declare Notice of Lien Void ab Initio by Defendant
United Central Bank. (Thill, Brian) Modified on 6/5/2014. (lak) (Entered:
06/04/2014)

06/04/2014

86 Disregard. See 88 . Modified on 6/5/2014: Requested document be refiled with
exhibit separated and described. (lak) (Entered: 06/04/2014)

06/04/2014

87 Certificate of Service by Defendant United Central Bank as to 85 Brief in Support,
84 Motion to Declare Notice of Lien Void ab Initio , 82 Brief in Opposition, 86
Affidavit, 83 Counterclaim. (Thill, Brian) (Entered: 06/04/2014)

06/05/2014

88 Sixth Affidavit of Brian P. Thill filed by Defendant United Central Bank re: 84
Motion to Declare Notice of Lien Void ab Initio, (Attachments:
# 1 Exhibit E-mail correspondence) (Thill, Brian) Modified on 6/5/2014. (lak)
(Entered: 06/05/2014)

06/17/2014

89 ORDER denying 81 Motion to Supplement Appeal Record ; Setting briefing on 84
Motion to Declare Notice of Lien Void ab Initio. Plaintiff has until 7/30/2014 to file
a response to the motion, Defendant may have until 8/20/2014 to file a reply. Signed
by District Judge William M. Conley on 6/17/2014. (voc) (Entered: 06/17/2014)

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Set Deadlines as to 84 Motion to Declare Notice of Lien Void ab Initio . Brief in
Opposition due 7/30/2014. Brief in Reply due 8/20/2014. (voc) (Entered:
06/17/2014)

06/17/2014

90 Transmission of Motion, Brief in Opposition and Order to Seventh Circuit Court of
Appeals re 76 Notice of Appeal. (Attachments:
# 1 Motion to Supplement the Appeal Record,
# 2 Brief in Opposition to Motion to Supplement the Appeal Record,
# 3 Order #89) (lak) (Entered: 06/17/2014)

06/26/2014

91 Motion for Extension of Time to obtain new counsel and to file Withdrawal and
Release of Lien by Interested Party Maurice James Salem. Motions referred to
Magistrate Judge Stephen L. Crocker. Response due 7/3/2014. (Salem, Maurice)
(Entered: 06/26/2014)

06/26/2014

92 Declaration of Maurice J. Salem filed by Interested Party Maurice James Salem re:
91 MOTION for Extension of Time (Attachments:
# 1 Withdrawal and Release of Lien) (Salem, Maurice) (Entered: 06/26/2014)

06/26/2014

93 ** TEXT ONLY ORDER **
For reasons explained exhaustively in previous opinions by this court, Attorney
Salem's pro se motion for extension of time (dkt. # 91 ) is summarily DENIED.
Signed by District Judge William M. Conley on 6/26/2014. (voc) (Entered:
06/26/2014)

06/30/2014

94 Proposed Findings of Fact filed by Counter Claimant United Central Bank re: 84
Motion to Declare Notice of Lien Void ab Initio. (Thill, Brian) Modified on
6/30/2014. (lak) (Entered: 06/30/2014)

06/30/2014

95 Motion for Entry of Default as to Trade Well International by Counter Claimant
United Central Bank. Motions referred to Magistrate Judge Stephen L. Crocker.
(Thill, Brian) Modified on 6/30/2014. (lak) (Entered: 06/30/2014)

06/30/2014

96 Affidavit of Brian P. Thill filed by Counter Claimant United Central Bank re: 95
Motion for Entry of Default. (Thill, Brian) (Entered: 06/30/2014)

06/30/2014

97 Proposed Entry of Default re 95 Motion for Entry of Default filed by United Central
Bank. (Thill, Brian) Modified on 6/30/2014. (lak) (Entered: 06/30/2014)

06/30/2014

98 Certificate of Service by Counter Claimant United Central Bank as to 94 Proposed
Findings of Fact, 97 Exhibit, 96 Affidavit, 95 Motion for Entry of Default as to
Trade Well International. (Thill, Brian) (Entered: 06/30/2014)

07/01/2014

Set Briefing Deadlines as to 95 Motion for Entry of Default as to Trade Well
International. Brief in Opposition due 7/10/2014. (voc) (Entered: 07/01/2014)

07/03/2014

99 Motion for Order to Show Cause by Defendant United Central Bank. Response due
7/10/2014. (Thill, Brian) (Entered: 07/03/2014)

07/03/2014

100 Certificate of Service by Defendant United Central Bank as to 99 Motion for Order
to Show Cause. (Thill, Brian) (Entered: 07/03/2014)

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07/10/2014

101 Brief in Opposition by Interested Party Maurice James Salem re: 95 Motion for
Entry of Default filed by United Central Bank, 99 Motion for Order to Show Cause
filed by United Central Bank, 84 Motion to Declare Notice of Lien Void ab Initio
filed by United Central Bank, (Attachments:
# 1 Appellant's Brief,
# 2 April 4, 2014, order on appeal,
# 3 April 22, 2014, order on appeal,
# 4 Appendix for Appellant, Part 1,
# 5 Appendix for Appellant, Part 2,
# 6 Appendix for Appellant, Part 3,
# 7 Appendix for Appellant, Part 4,
# 8 Appendix for Appellant, Part 5,
# 9 Appendix for Appellant, Part 6) (Salem, Maurice) Modified on 7/11/2014. (lak)
(Entered: 07/10/2014)

07/10/2014

102 Brief in Opposition by Interested Party Maurice James Salem re: 99 Motion for
Order to Show Cause filed by United Central Bank to Strike Plaintiff's Pleadings.
(Salem, Maurice) (Entered: 07/10/2014)

08/20/2014

103 Certificate of Service by Counter Claimant United Central Bank as to 71 Order on
Motion to Compel, Order on Motion to Strike. (Thill, Brian) (Entered: 08/20/2014)

08/20/2014

104 Brief in Reply by Counter Claimant United Central Bank in Support of 99 Motion
for Order to Show Cause, 84 Motion to Declare Notice of Lien Void ab Initio, 95
Motion for Entry of Default. (Thill, Brian) Modified on 8/20/2014. (lak) (Entered:
08/20/2014)

08/20/2014

105 Certificate of Service by Counter Claimant United Central Bank as to 104 Brief in
Reply. (Thill, Brian) (Entered: 08/20/2014)

09/12/2014

106 ORDER granting 95 Motion for Entry of Default. Granting 99 Motion for Order to
Show Cause. Plaintiff is ordered to show cause by 10/3/2014, as to why its case
should not be dismissed for failure to prosecute. An Evidentiary Hearing for default
judgment is scheduled for 10/16/2014 at 1:00 PM. Attorney Salem's sanction is
increased by $500, making the total amount due to UCB $1,000. The Clerk of Court
is instructed to accept no further filings in this case from Salem absent leave of the
court unless they relate solely to the imposition of this additional sanction against
him personally. Signed by District Judge William M. Conley on 9/12/2014. (voc)
(Entered: 09/12/2014)

09/12/2014

Set Deadlines/Hearings: Evidentiary Hearing set for 10/16/2014 at 01:00 PM. (voc)
(Entered: 09/12/2014)

10/07/2014

107 Certified and Transmitted Record on Appeal to US Court of Appeals re: 76 Notice
of Appeal, (Attachments:
# 1 Certification) (lak) (Entered: 10/07/2014)

10/09/2014

108 Trial Brief for October 16, 2014 Evidentiary Hearing by Counter Claimant United
Central Bank (Thill, Brian) Modified on 10/10/2014 (voc). (Entered: 10/09/2014)

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10/09/2014

109 Proposed Exhibit List for October 16, 2014 Hearing by Counter Claimant United
Central Bank. (Attachments:
# 1 Exhibit 1 - Initial proposed settlement statement,
# 2 Exhibit 2 - Notice of Lien,
# 3 Exhibit 3 - Rejection of closing,
# 4 Exhibit 4 - Final settlement statement,
# 5 Exhibit 5 - Attorneys' fees itemization,
# 6 Exhibit 6 - Costs itemization) (Thill, Brian) Modified on 10/14/2014. (lak)
(Entered: 10/09/2014)

10/10/2014

110 Certificate of Service by Counter Claimant United Central Bank as to 109 Exhibit
List, 108 Trial Brief. (Thill, Brian) (Entered: 10/10/2014)

10/16/2014

111 Affidavit of Bruce Lowrey of Service of Subpoena to Appear and Testify at a
Hearing or Trial in a Civil Action upon Tara M. Jauch. (Thill, Brian) (Entered:
10/16/2014)

10/16/2014

112 Minute Entry for proceedings held before District Judge William M. Conley:
Default Hearing held on 10/16/2014: Default judgment to be entered against
plaintiff. [:20] (Court Reporter LS.) (rep) (Entered: 10/16/2014)

10/16/2014

113 ORDER dismissing plaintiff Trade Well International's claims, declaring the lien
entered against the subject property null and void, and entering default judgmentin
the total amount of $3,785.90 plus attorney fees and costs. Signed by District Judge
William M. Conley on 10/16/14. (rep) (Entered: 10/16/2014)

10/16/2014

114 Affidavit of Brian P. Thill in Support of Judgment. (Thill, Brian) Modified on
10/17/2014: Attorneys' Fees not attached separately. (lak) (Entered: 10/16/2014)

10/17/2014

115 ** TEXT ONLY ORDER **
Based on the supplemental submission of counsel for defendant United Central
Bank (dkt. # 114 ), and for the reasons stated at yesterday's hearing on default
judgment, the court determines that the reduced amounts of $26,271.75 in attorney
fees and $247.02 in costs are reasonable calculations of actual damages sustained by
defendant in clearing title to its property. The clerk is directed to enter default
judgment consistent with this order and with the court's previous opinion and order
of October 16, 2014 (dkt. # 113 ). Signed by District Judge William M. Conley on
10/17/14. (rep) (Entered: 10/17/2014)

10/27/2014

116 JUDGMENT in favor of United Central Bank against Trade Well International in
the amount of $ 30,304.67. (PAO/WMC). Signed by District Judge William M.
Conley on 10/24/2014. (voc) (Entered: 10/27/2014)

02/17/2015

117 Notice of Appearance filed by Maurice J. Salem for Counter Defendant Trade Well
International, Plaintiff Trade Well International. (Salem, Maurice) (Entered:
02/17/2015)

02/18/2015

118 Motion for Recusal of Judge William M. Conley by Counter Defendant Trade Well
International, Plaintiff Trade Well International. Response due 2/25/2015. (Salem,
Maurice) (Entered: 02/18/2015)

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02/18/2015

119 Brief in Support of 118 Motion for Recusal by Counter Defendant Trade Well
International, Plaintiff Trade Well International. (Salem, Maurice) (Entered:
02/18/2015)

02/18/2015

120 Affidavit of Maurice James Salem filed by Counter Defendant Trade Well
International, Plaintiff Trade Well International In Support re: 118 Motion for
Recusal. (Salem, Maurice) Modified on 2/19/2015. (lak) (Entered: 02/18/2015)

02/19/2015

121 Proposed Order re: 118 Motion for Recusal filed by Trade Well International.
(Salem, Maurice) Modified on 2/20/2015. (lak) (Entered: 02/19/2015)

02/25/2015

122 Brief in Opposition by Defendant United Central Bank re: 118 Motion for Recusal
filed by Trade Well International. (Thill, Brian) (Entered: 02/25/2015)

03/05/2015

123 JUDGMENT from USCA vacating the orders holding Maurice James Salem in
contempt and imposing sanctions re: 76 Notice of Appeal, filed by Trade Well
International. No record to be returned. (Attachments:
# 1 Mandate,
# 2 Appellate Opinion) (kwf) (Entered: 03/05/2015)

03/17/2015

124 ORDER - Pursuant to the opinion and mandate of the Court of Appeals for the
Seventh Circuit, it is ordered that: 1. All monetary sanctions entered against
plaintiff's trial counsel, Maurice J. Salem,are vacated, including the second $500
sanction not the subject of that appeal. 2. Attorney Maurice J. Salem's pro hac vice
appearance for plaintiff in this case is reinstated. 3. The clerk of court is directed to
send a copy of this order and the Seventh Circuit Court of Appeals decision to the
enforcement authorities responsible for the practice of law in the States of
Wisconsin and New York. 4. The undersigned recuses himself in the above entitled
matter pursuant to 28U.S.C. § 455. District Judge William M. Conley recused. Case
reassigned to District Judge James D. Peterson for all further proceedings. Signed by
District Judge William M. Conley on 3/16/2015. (voc) (Entered: 03/17/2015)

03/26/2015

125 Motion to Vacate Orders Granting Default Judgment on the Counterclaim, (dkt.
#106), Nullifying a Lien and Dismissing this Action (dkts. #113 & 116) by Counter
Defendant Trade Well International, Plaintiff Trade Well International. Response
due 4/2/2015. (Attachments:
# 1 Proposed Order) (Salem, Maurice) (Entered: 03/26/2015)

03/26/2015

126 Brief in Support of 125 Motion to Vacate, Orders Granting Default Judgment on the
Counterclaim, (dkt. #106), Nullifying a Lien and Dismissing this Action (dkts. #113
& 116) by Counter Defendant Trade Well International, Plaintiff Trade Well
International. (Salem, Maurice) (Entered: 03/26/2015)

03/26/2015

127 Affidavit of Maurice James Salem filed by Counter Defendant Trade Well
International, Plaintiff Trade Well International re: 125 Motion to Vacate. (Salem,
Maurice) (Entered: 03/26/2015)

04/02/2015

128 Brief in Opposition by Defendant United Central Bank re: 125 Motion to Vacate,
filed by Trade Well International. (Thill, Brian) (Entered: 04/02/2015)

04/02/2015

129 Motion to Strike 127 Affidavit (inadmissible or conclusory portions) by Defendant
United Central Bank. Brief in Opposition due 4/16/2015. Brief in Reply due

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4/23/2015. (Thill, Brian) (Entered: 04/02/2015)
08/27/2015

130 ORDER Setting Hearing on Motion 125 Motion to Vacate Orders Granting Default
Judgment on the Counterclaim, (dkt. #106), Nullifying a Lien and Dismissing this
Action (dkts. #113 & 116) : Motion Hearing set for 9/17/2015 at 11:00 AM in
courtroom 360. Plaintiff must submit any exhibits that it plans to offer at the hearing
by September 10, 2015. Signed by District Judge James D. Peterson on 8/27/2015.
(voc) Modified on 8/27/2015. (lak) (Entered: 08/27/2015)

09/10/2015

131 Brief in Reply by Counter Defendant Trade Well International, Plaintiff Trade Well
International in Support of 125 Motion to Vacate Orders Granting a Default
Judgment on Counterclaim, (dkt. #106), Nullifying a Lien and Dismissing this
Action, (dkts. #113 & 116) (Attachments:
# 1 Exhibit A - Trade Well's Affidavit (Also see 132 .),
# 2 Exhibit B - Salem's Attorney list,
# 3 Exhibit C - Paracha's notes,
# 4 Exhibit D - Paracha's Attorney) (Salem, Maurice) Modified on 9/11/2015. (lak)
(Entered: 09/10/2015)

09/14/2015

132 Affidavit of Muhammad Tahir filed by Counter Defendant Trade Well International,
Plaintiff Trade Well International in Support re: 125 Motion to Vacate. (Salem,
Maurice) . (Entered: 09/14/2015)

09/16/2015

133 Response to Proposed Conclusions of Law filed by Counter Defendant Trade Well
International, Plaintiff Trade Well International re: 125 Motion to Vacate, filed by
Trade Well International. (Salem, Maurice) (Entered: 09/16/2015)

09/17/2015

134 Minute Entry for proceedings held before District Judge James D. Peterson: Motion
Hearing held on 9/17/2015 re 125 Motion to Vacate Orders Granting Default
Judgment on the Counterclaim, (dkt. #106), Nullifying a Lien and Dismissing this
Action (dkts. #113 & 116) filed by Trade Well International (Court Reporter CS.)
(nln) [1:45] (Entered: 09/17/2015)

09/24/2015

135 ORDER: Plaintiff Trade Well International's motion to vacate orders granting
default judgment on the counterclaim, nullifying a lien, and dismissing this action,
Dkt. 125 , is denied. Defendant United Central Bank's motion to strike, Dkt. 127 , is
denied as moot. Signed by District Judge James D. Peterson on 9/23/2015. (voc)
(Entered: 09/24/2015)

10/22/2015

136 NOTICE OF APPEAL by Counter Defendant Trade Well International, Plaintiff
Trade Well International as to 135 Order on Motion to Vacate, Order on Motion to
Strike. Filing fee of $ 505, receipt number 0758-1669591 paid. Docketing Statement
filed. (Attachments:
# 1 Docketing Statement) (Salem, Maurice) (Entered: 10/22/2015)

10/23/2015 7:06 AM