Appellant is seeking a forty-five-day extension of time until July 3, 2023, to file his opening brief pursuant to Local Circuit Court 26 where undersigned counsel is unable to adequately consult with her client prior to the current due date and she is engaged in an exceptional amount of other litigation fully explained in counsel’s attached declaration.

Between May 10, 2023 and May 17, 2023, undersigned counsel has four depositions in the matter of Ochoa v. Lopez, 20-cv-02977 (N.D. Ill.) which cannot be rescheduled as there is an impending fact discovery deadline of June 30, 2023, in that case.

Furthermore, and most importantly, Mr. Kelly was transferred from the Metropolitan Correctional Center in Chicago, Illinois to FCI Butner in North Carolina on or around April 24, 2023.

As the United State Supreme Court has held “the need for forceful advocacy does not come to an abrupt halt as the legal proceeding moved from the trial to appellate stage.

With these principles in mind, undersigned counsel needs adequate time to consult with Mr. Kelly in order to competently represent him on direct appeal.

SERVICES, INC, a New Jersey Corporation; and DOES 1 through 10, inclusive,

WELLNESS CENTER, LLC, a California limited liability company; et al. Counter-Claim Defendants.

Case 2:23-cv-00859-GW-SK Document 232 Filed 09/03/24 Page 2 of 2 Page ID #:5187 On September 3, 2024, the Parties filed a Stipulation to Dismiss With Prejudice.

The Court, having considered the Parties’ Stipulation and finding good cause, hereby GRANTS the Stipulation to Dismiss With Prejudice and ORDERS as follows: 1.

The matter is dismissed with prejudice, each Party to bear their own costs and attorney’s fees.

Christopher G. Conway Clerk of the United States Court of Appeals for the Seventh Circuit 219 South Dearborn Street, 27th Floor Chicago, Illinois 60604

Re: United States v. Robert S. Kelly No. 23-1449 Dear Mr. Conway, This letter respectfully requests that the Clerk consider the schedule of counsel for Defendant-Appellant Robert S. Kelly in setting the oral argument date in this appeal.

No date is currently scheduled.

Counsel for the Defendant-Appellant respectfully requests that oral argument not be set for January 10, 16, 19, 22 - 23, February 20, 26-29 or March 21-24, because counsel has other unmovable deadlines, or will be out of office.

United States Attorney Northern District of Illinois Dirksen Federal Building 219 South Dearborn Street, Fifth Floor Chicago, Illinois 60604

Brian Williamson Assistant United States Attorney

Christopher G. Conway Clerk of the United States Court of Appeals for the Seventh Circuit 219 South Dearborn Street 27th Floor Chicago, Illinois 60604 Re: United States v. Robert S. Kelly No. 23-1449

This letter respectfully requests that the Clerk take into account the schedule of the counsel for the government in setting the oral argument date in this appeal (no date has yet been scheduled).

Counsel for the government respectfully requests that oral argument not be set for February 5-9 and April 8-17, 2024, because counsel will be either in trial or out of the office.

And while defendant conceded he had been convicted of “serious offenses,” he nonetheless pushed for a sentence at the low end of the Guidelines range by downplaying defendant’s sexual abuse of Jane and his other minor victims.

28 Case: 23-1449 Document: 26 Filed: 12/14/2023 Pages: 56 Defendant nonetheless asks this Court to cast aside the well-reasoned analysis set out in Maxwell and, in effect, to overturn Gibson and contravene the Supreme Court’s ...

And while defendant conceded he had been convicted of “serious offenses,” he nonetheless pushed for a sentence at the low end of the Guidelines range by downplaying defendant’s sexual abuse of Jane and his other minor victims.

28 Case: 23-1449 Document: 24 Filed: 12/14/2023 Pages: 56 Defendant nonetheless asks this Court to cast aside the well-reasoned analysis set out in Maxwell and, in effect, to overturn Gibson and contravene the Supreme Court’s ...

Appellant is seeking a thirty-day extension of time until May 18, 2023, to file his brief pursuant to Local Circuit Court Rule 26 for several reasons fully explained in counsel’s attached declaration.

Due to an extensive caseload of over 60 cases, undersigned counsel is predominantly responsible for digesting the record, drafting the brief and consulting with Mr. Kelly prior to filing.

That appeal stems from Mr. Kelly’s September 27, 2021, convictions for racketeering and multiple Mann Act violations following a six-week jury trial in the Eastern District of New York.

Due to other personal and professional obligations, undersigned counsel will be unable to visit with Mr. Kelly again prior to April 18 to review his Seventh Circuit brief as well.

As the United State Supreme Court has held “the need for forceful advocacy does not come to an abrupt halt as the legal proceeding moved from the trial to appellate stage.

On July 29, 2024, Plaintiff All American Healthcare Services, Inc. initiated this action against several Defendants.

For purposes of diversity jurisdiction, “an LLC is a citizen of every state of which its owners/members are citizens.” Johnson v. Columbia Props.

Similarly, “a limited partnership is a citizen of all of the states of which its partners are citizens.” Lindley Contours, LLC v. AABB Fitness Holdings, Inc., 414 F. App’x 62, 64 (9th Cir. 2011).

In the Complaint, as to Defendants who are LPs or LLCs, Plaintiff states only that the Defendant is a “California limited liability company with its principal place of business at [a California address]” or Defendant is a “California limited partnership with a principal place of business at [a California address].” (See Compl.

Accordingly, Plaintiff is ORDERED to show cause, in writing not to exceed four pages, why the Court should not remand this action to state court for lack of subject matter jurisdiction.

USCA11 Case: 23-10126 Document: 33 Date Filed: 03/15/2023 Page: 3 of 10 North American Sugar Industries Inc. v. Xinjiang Goldwind Science & Technology Co., LTD., et.

USCA11 Case: 23-10126 Document: 33 Date Filed: 03/15/2023 Page: 4 of 10 North American Sugar Industries Inc. v. Xinjiang Goldwind Science & Technology Co., LTD., et.

USCA11 Case: 23-10126 Document: 33 Date Filed: 03/15/2023 Page: 5 of 10 North American Sugar Industries Inc. v. Xinjiang Goldwind Science & Technology Co., LTD., et.

Sugar”) Miguel A. Estrada, Rahim Moloo, Jeremy M. Christiansen, M. Christian Talley, and the law firm of Gibson, Dunn & Crutcher LLP, respectfully move this Court to enter an order allowing their withdrawal as counsel of record for American Sugar.

American Sugar consents to its counsel from the law firm of Gibson, Dunn & Crutcher LLP withdrawing from this matter, and has been provided with a copy of this motion.

SERVICES, INC, a New Jersey Corporation; and DOES 1 through 10, inclusive,

SERVICES, INC, a New Jersey Corporation Counter-Claim Plaintiff,

Plaintiffs/Counter-Claim Defendants Granite Hills Healthcare & Wellness Centre, LLC; Anaheim Point Healthcare & Wellness Centre, LP; Skyline Healthcare & Wellness Center, LLC; San Pablo Healthcare & Wellness Center, LLC; Lawndale Healthcare & Wellness Centre, LLC; Grand Avenue Healthcare & Wellness Centre, LP; and Verdugo Valley Skilled Nursing & Wellness Centre, LLC have served offers of judgment upon Defendant/Counter-Claim Plaintiff All American Healthcare Services, Inc., which offers of judgment have been accepted by All American Healthcare Services, Inc.

IT IS HEREBY ORDERED as follows:  Judgment is granted for All American Healthcare Services, Inc. and against Granite Hills Healthcare & Wellness Centre, LLC in the amount of $51,449.01;  Judgment is granted for All American Healthcare Services, Inc. and against Anaheim Point Healthcare & Wellness Centre, LP in the amount of $138,765.41;  Judgment is granted for All American Healthcare Services, Inc. and against Skyline Healthcare & Wellness Center, LLC in the amount of $26,008.26;  Judgment is granted for All American Healthcare Services, Inc. and against San Pablo Healthcare & Wellness Center, LLC in the amount of $11,924.84;  Judgment is granted for All American Healthcare Services, Inc. and against Lawndale Healthcare & Wellness Centre, LLC in the amount of $4,739.21;  Judgment is granted for All American Healthcare Services, Inc. and against Grand Avenue Healthcare & Wellness Centre, LP in the amount of $135,613.82;  Judgment is granted for All American Healthcare Services, Inc. and against Verdugo Valley Skilled Nursing & Wellness Centre, LLC in the amount of $294,680.36; IT IS FURTHER ORDERED that all claims asserted by Plaintiffs/Counter-Claim Defendants Granite Hills Healthcare & Wellness Centre, LLC; Anaheim Point Healthcare & Wellness Centre, LP; Skyline Healthcare & Wellness Center, LLC; San Pablo Healthcare & Wellness Center, LLC; Lawndale Healthcare & Wellness Centre, LLC; Grand Avenue Healthcare & Wellness Centre, LP; and Verdugo Valley Skilled Nursing & Wellness Centre, LLC against Defendant/Counter-Claim Plaintiff All American Healthcare Services, Inc. are hereby dismissed with prejudice.

United States District Judge

This matter comes before the Court on Counterclaim Defendants’ Motion to Take Judicial Notice (Doc. #320) filed on February 15, 2024.

“Since the effect of taking judicial notice under Rule 201 is to preclude a party from introducing contrary evidence and in effect, directing a verdict against him as to the fact noticed, the fact must be one that only an unreasonable person would insist on disputing.” United States v. Jones, 29 F.3d 1549, 1553 (11th Cir. 1994).

A district court may take judicial notice of public records, but “[s]uch documents should be considered only for the purpose of determining what statements the documents contain, not to prove the truth of the documents' contents.” Bryant v. Avado Brands, Inc., 187 F.3d 1271, 1277 (11th Cir. 1999)(alteration in original)(quoting Lovelace v. Software Spectrum Inc., 78 F.3d 1015, 1018 (5th Cir. 1996))(explaining that “[w]hen SEC documents are relevant only to determine what statements or disclosures are actually contained therein, there can be little question as to authenticity, nor can the fact that such statements or disclosures were thus publicly filed be reasonably questioned.”).

“In a civil case, the court must instruct the jury to accept the noticed fact as conclusive.” Fed. R. Evid.

Counterclaim Defendants’ Motion to Take Judicial Notice (Doc. #320) is GRANTED to the limited extent set forth above.