The newspaper found the company was using a permit with an expiration date in 1988, a permit the Forest Service hadn't reviewed . Contacting Justia or any attorney through this site, via web form, email, or otherwise, does not create an attorney-client relationship. And the best part of all, documents in their CrowdSourced Library are FREE! If you do not agree with these terms, then do not use our website and/or services. San Bernardino District Courthouse Civil Division, LAW OFFICES OF SANTA CRUZ, BROWNWOOD & CANN, BERMAN BERMAN BERMANSCHNEIDER & LOWARY LLP. 0N;y$.BED$H.Q( za Imposing a strict ban on short term renters' access to the lake and walking trails is short sighted. jfrG ]5vJ$:JpEKtP)^PGfdyWNTCh]z1:tzig|{c$t_; .pkWXV+7=6QiH \l6zQ6=|*{^P}5[72_ Verdict: The court ruled that the election was invalid and ordered a new election. 2023-01-26. Vertical Web Ventures, Inc. et al v. Arrowhead Lake Association et al, VERTICAL WEB VENTURES, INC., ETAL -v- ARROWHEAD LAKE ASSOCIATION, ETAL, MICHELLE ALEJANDRA GOMEZ -v- EDGAR ALFONSO GOMEZ, Kearney v. Safeco Insurance Company of Illinois, Peery v. Safeco Insurance Company of Indiana et al, WAUTHION vs SAFECO INSURNACE COMPANY OF AMERICA. The dock insurance program will be administered and run by Arrowhead Lake Associations insurance agency, Shaw, Moses, Mendenhall & Associates. (Donohue's Brief in Support of Application for Counsel Fees at 4, 10.). top of page. Most courts either encourage or mandate that parties atleast participate in a settlement meeting. Donohue claims that the Association's appeal is frivolous, because (1) the issue raised on appeal was not preserved for appellate review, (2) Donohue's right to the meeting was clear and the Association offered no defense to the merits of the claim, and (3) the Association continued to pursue this appeal despite that fact that the special meeting was held in December of 1997. DocketSummons Issued and Filed; Comment: SUMMONS ISSUED AND FILED, DocketComplaint and Party Information Entered; Comment: COMPLAINT AND PARTY INFORMATION ENTERED, U.S. District Courts | Civil Right | John DONOHUE v. ARROWHEAD LAKE COMMUNITY ASSOCIATION, Appellant. Arrowhead Lake Association protects and operates Lake Arrowhead . If this bylaw amendment is accepted, the economy of our holiday community will be affected on many levels. The text of the proposed amendment was included in the Petition. 8:23-CV-00409 | 2023-02-23, U.S. District Courts | Contract | (SUBMITTED ATTACHED TO NOTICE OF REMOVAL #1 ) (lh), NON-CONFORMED COPY of ANSWER to Second Amended Complaint, filed by Defendants Gary Clifford, Eran Heissler, Christopher Wilson, Anthony Okeefe, Robert Mattison, Alan B. Kaitz. The first Arrowhead Lake Association (ALA) board meeting for 2022 took place last Saturday at Burnt Mill Clubhouse at 9 a.m. All directors were present, along with general manager Bob Mattison and secretary Sharon Pittman, and director David Dahl attended the meeting virtually. DocketPlaintiff First Paper Fee Previously Paid in Full; Comment: PLAINTIFF LISA DAILY, CHRYSTAL KENNELLY FIRST PAPER FEE PREVIOUSLY PAID IN FULL. Pa. R.A.P. We are currently collect data for this state. One way or the other a decision will be made. Accessing Verdicts requires a change to your plan. Since you're a guest, you can punch in a guest code to get in. MARRSHA LOSEY-SILL VS GEVIK MARCARIAN, D.D.S., AN INDIVIDUAL, ET AL. Your subscription was successfully upgraded. The Association, however, never produced any evidence at all on its behalf; nor did it present a cogent defense. (SUBMITTED ATTACHED TO NOTICE OF REMOVAL #1 ) (lh), NON-CONFORMED COPY OF ANSWER to Third Amended Complaint, filed by Defendant Brian C. Hall. The coalition of advocacy organizations filed a lawsuit on Friday in a last-ditch effort to block the development, which they argue will wipe out an important ecosystem. THANK YOU. Donohue circulated the Petition in response to a decision pending before the Board of Directors regarding whether to spend a minimum of 16 million dollars to upgrade and expand the Association's sewer system. 2021-07-28, San Bernardino County Superior Courts | Property | Legacy Minutes; Comment: JURY TRIAL -- ESTIMATED TRIAL LENGTH HOURS. Access this case on the California Central District Court's Electronic Court Filings (ECF) System. On 07/28/2021 VERTICAL WEB VENTURES, INC , ETAL filed a Property - Other Real Property lawsuit against ARROWHEAD LAKE ASSOCIATION, ETAL. No. Arrowhead Lakes, PA Homes for Sale & Real Estate 70 Homes Available Tile Sort by 11 162 Ski Tr, Pocono Lake, PA 18347 3 Beds 2 Baths 1,644 Sqft 0.33 ac Lot Size Residential $299,000 USD View Details 59 112 TROUT Creek, Pocono Lake, PA 18347 2 Beds 1 Bath 977 Sqft 0.32 ac Lot Size Residential $365,000 USD View Details 9 ), DocketRequest for Dismissal Filed; Comment: REQUEST FOR DISMISSAL FILED- WITH PREJUDICE. REQUEST FOR DISMISSAL FILED- WITH PREJUDICE. Under Pa. R.A.P. (Subcribe to view) This docket was last retrieved on August 25, 2022. You have used out of 0 document requests this month. BBK is familiar with the legal history of the Association. 238127 scott.ditfurth@bbklaw.com *Gregg W. Kettles, Bar No. In 2009, the Association imposed an assessment . Community associations with unenforced deed restrictions can enforce them - even after 82 years! In short, pursuant to thepreliminary injunction, STRS are not allowed to use any facility that is not covered by the 1964Agreement. Legacy Minutes; Comment: READINESS CALENDAR, Readiness Calendar; Original Type: Readiness Calendar; Hearing Time: 8:30 AM; Cancel Reason: Vacated; Comment: READINESS CALENDAR, CONV; Total Financial Assessment: $1,910.00; Total Payments and Credits: $1,910.00. (Notes of Testimony (N.T.) lake arrowhead news. The Association states: In order to hold a special meeting, many difficult and costly steps must be taken. 170640 gregg.kettles@bbklaw.com By continuing to use this website, you agree to UniCourts General Disclaimer, Terms of Service, Please try again. Membership will get to meet the Board of Directors at the Lake Arrowhead Chamber's Annual Membership Meeting which will be held in February 2023. 92352 (909) 844-7261 Why is this public record being published online? Certificate of Assignment Received; Comment: CERTIFICATE OF ASSIGNMENT RECEIVED. Conifer Wonder Lodge, LLC (Entity #20231209362) is a Limited Liability Company in Conifer, Colorado registered with the Colorado Department of State (CDOS). Arrowhead Lake Association Practice area: HOA Description: We represented the Plaintiff in this case. The amenities are wonderful. Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. Civil Case Cover Sheet Filed; Comment: CIVIL CASE COVER SHEET FILED. If not on Arrowhead Lake Community Association's sewer system, a septic system inspection report showing the existing system is functioning, and proof that the tank was pumped in accordance with the Arrowhead Lake Community Association Rules and Regulations. [ASSOCIATION'S COUNSEL]: I agreed the signatures matched. Proposed Bylaw/Policy/Rules Amendments/Revisions, https://www.ala-ca.org/legal_information.php, Lake Operations & Maintenance Committee @ 2:30 PM - CANCELLED DUE TO WEATHER, Forest & Vegetation Committee Meeting @ 9:00 AM. "That begs the question: Do you have any personal property rights that are still valid under CEQA?" 0 Since the Association's issue is being raised for the first time on appeal, it is waived. If you wish to keep the information in your envelope between pages, This appeal by the association was filed on October 17, 1997. Lake Arrowhead Queen. Arrowhead Lake Community Association is a privately-owned, gated community located in the beautiful Pocono Mountains of Pennsylvania. Original Summons NOT returned. Your docket refresh request has been received. We expect the Appeals Court to render a decision in late2023. We are checking for the latest updates in this case. The Association's Bylaws provide that a special meeting may be called upon the written petition of five-percent of the Members of the Association who would have the right to vote at such special meetings. (Article VIII, Section 3, of the Bylaws.) The individual board members are represented by D.Wayne Leech of the Law Office of D. Wayne Leech. Ochoa found that the Arrowhead Lake Association 's 2020 bylaw change, which prevented short-term renters from using the lake or the area's reserve strips, is likely to be proved to violate the association's 1964 Settlement Agreement. The Defendant association claimed the election was valid. Judgment; Judgment Type: Dismissal - Request for Dismissal; Comment; Comment: (REQUEST FOR DISMISSAL FILED- WITH PREJUDICE. Conservation groups are refusing to give up their fight against a church's controversial plan to build a campus on an undeveloped property in a forest near Lake Arrowhead. Combined, pit bulls and rottweilers contributed to 76% of the total recorded deaths. We will email you this document within 4 business hours. Pit bulls contributed to 66% (346) of these deaths. 1983, wherein he alleges the defendants, acting under color of state law, deprived him of his civil rights. "The County is violating the law by accepting this proposal's flawed Environmental Impact Report.". Copy of a valid Short-Term Rental license or permit from Tobyhanna/Coolbaugh Township. CIVSB2120604 Before the Honorable Gilbert Ochoa APPELLANT ARROWHEAD LAKE ASSOCIATION'S OPENING BRIEF Scott W. Ditfurth, Bar No. 2:22-CV-05209 | 2022-07-27, San Bernardino County Superior Courts | Property | will be able to access it on trellis. hb```f~.Ad`0pl`XjPW_ P `e`U@, ` R73Nb4.O{0053ur00 6400$mf`^ e` [" If it ultimately moves forward, the campus will include a 41,000-square-foot assembly building, a 27,000-square-foot youth center, a soccer field and and a parking lot with several hundredspaces. DocketJury Trial; Original Type: Jury Trial; Hearing Time: 10:00 AM; Cancel Reason: Vacated; Comment: JURY TRIAL -- ESTIMATED TRIAL LENGTH HOURS. Furthermore, because the special meeting had been convened, the Association's decision to continue to pursue this appeal, thereby incurring further costs, is plainly unreasonable, if its argument was that it took the appeal in the first place to conserve costs. The officers of the Association, however, did not call the special meeting. Wds 1 2017 form. to use Lake Arrowhead and the Association Properties without becoming an ALA member, paying an Annual Fee or in any way contributing to the maintenance . David Wert, San Bernardino County spokesperson, said the county had not been served the court papers, so he was unable to comment on specific allegations in the complaint. 0:57. Contact us. This litigation concluded with a communitycompromise. Prior to the meeting, expenses accrue related to sending notice of the meeting. The Arrowhead Lake Community Association (Association) appeals an order of the Court of Common Pleas of Monroe County, which directed the Association to hold a special meeting of the Association's membership and assessed counsel fees against the Association. Nm+lY.jZamzv8?? We noticed that you're using an AdBlocker. That was the foundation of Appellant's argument at the lower court. 8H Qa /3Ua !=[z+fZ}QN6kC/f3t ? ? awac permit lake arrowhead cc&r lake arrowhead marina lake arrowhead access lake arrowhead official website arrowhead lake association rules arrowhead lake association lawsuit lake arrowhead home owners association. So says a Morris County Superior Court Judge after a recent trial in a case entitled Unfair Share Lake Arrowhead 2010, Inc. v. Lake Arrowhead Club, Inc. 73 complainants Lake Arrowhead has 242 homes. The Associations property is privateproperty and not open to the public. In addition to filing a lawsuit, the plaintiffs sought apreliminary injunction against ALA, seeking to prohibit the enforcement of the bylaw revision. | More in the jurisdiction of San Bernardino County. Filing Fee Paid by; Comment: FILING FEE PAID BY LISA DAILY, CHRYSTAL KENNELLY FOR NEW FILING 170829-0995-CK CVH/ 435.00 PAYMT 170829-0995-CK REFERENCE NUMBER 119393. All Rights Reserved. Get free summaries of new Supreme Court of Missouri opinions delivered to your inbox! ANSWER FILED BY SAFECO INSURANCE COMPANY OF AMERICA; PARTY REPRESENTED BY SANTA CRUZ, BROWNWOOD & CANNON. 5755, which states that a special meeting may be called by members entitled to cast at least 10% of the votes which all members are entitled to cast at the particular meeting Donohue procured 999 signatures of Association members on his petition. In fact, the 700 individuals who signed the Petition constituted more than twenty-one percent of the 3,200 members of the Association, much more than the five-percent required by the Bylaws and the ten-percent required under the Law. it determines that an appeal is frivolous or taken solely for delay or that the conduct of the participant against whom costs are to be imposed is dilatory, obdurate or vexatious. Learn more. Short term renters increased the Associations liability and costs and impacted members enjoyment. The program provides property and general liability insurance coverage for single, double, triple, quad, and multi-slip docks. Conservation groups are refusing to give up their fight against a church's controversial plan to build a campus on an undeveloped property in a forest near Lake Arrowhead. This high-elevation drive is passable throughout the year, though drivers must carry tire chains in the winter. Fifty-seven percent of residents said we should . These expenses include postage, stationary, administrative drafting, and envelope stuffing [and] sealing. This would, of course, be in addition to any counsel fees previously awarded to Donohue against the Association by Common Pleas for the obdurate conduct of the Association up to the date the trial court's order was entered. A fire tore through a boat dock in Lake Arrowhead early Friday morning, destroying seven boats and causing an estimated $2 million in damage to the dock and other vessels, according to . He has given me a petition. at 24; Reproduced Record (R.R.) Subscribe now for free for access to all of Follow Our Courts content. Public Records Policy. 2021, ``ENVIRONMENTAL JUSTICE FOR ALL ACT'' ===== LEGISLATIVE HEARING before the COMMITTEE ON NATURAL RESOURCES U.S. HOUSE OF REPRESENTATIVES ONE HUNDRED SEVENTEENTH CONGRESS SECOND SESSION _____ Tuesday, February 15, 2022 _____ Serial No. 2016AP2112 1 BLANCHARD, J.1 This is the latest in a series of appeals involving the Lake Arrowhead Association, Inc., a homeowners' association.2 In this case, the Association filed small claims suits against four owners of residential lots in Lake ArrowheadThomas Wilkes, Richard Wilkes, Gilbert Ewer, and Linda Ewer ("the . Prior to 2020, short term renters that were clients of Arrowhead Woods propertyowners had access to Association property. Subscribe for free to get access to all of Follow Our Courts content. Therefore, in light of the above, we hold that the Common Pleas Court did not erroneously place the burden of proof on the Association, but rather properly determined that the Association had to go forward with the evidence to rebut Donohue's prima facie case that the Association was required to convene a special meeting as provided by the Bylaws and the Law. 5. Mr. Garrison, Mr. Scafiddi, and Mr. Leechhandled the initial phases of the lawsuit, as well as the preliminary injunction. On May 3, 1997, Donohue attended a meeting of the Association, presented the signed Petitions, and requested that a special meeting be called to consider the amendment of the Bylaws as proposed in the Petition. Sensible and responsible rules and regulations are needed. Your credits were successfully purchased. ", He called on the county to "accurately assess the full impacts of this project to avoid permanent harm to our community, visitors, the forest and its wildlife.". In 2021, the Arrowhead Lake Association, along with ALA Board members, were sued by !*"^nedKBG$[Eb"H,As9g[9/1p>)M%y4vWh79_8Z&onk 4?= Justia makes no guarantees or warranties that the annotations are accurate or reflect the current state of law, and no annotation is intended to be, nor should it be construed as, legal advice. The Arrowhead Lake Association initially retained Gregory Garrison from Gregory M.Garrison, APC and Michael Scafiddi from the Law Offices of Michael A. Scafiddi regarding thelawsuit and preliminary injunction. To that end, and in the spirit oftransparency, the legal documents, including the injunction itself, are available for memberreview at https://www.ala-ca.org/legal_information.php. In response, the Association argues that it had a good faith reason for prosecuting this appeal, since it has an important financial interest in limiting the availability of special meetings. boating; sailing; fishing; hiking; biking; camping; more fun; . 04/18/2019: NOTICE OF RETURN OF DOCUMENT(S), 04/17/2019: REQUEST FOR DISMISSAL FILED- WITH PREJUDICE. Therefore, we will affirm the Common Pleas Court's order. If youd like to access verdicts right away, please enter your information below Furthermore, at the hearing Common Pleas directed the parties to compare the signatures on the Petitions to the Association's records to verify whether those individuals were members in good standing. Most important, the Association conceded that 700 of the signatures on the Petitions were members in good standing of the Association: THE COURT: Counsel, how did you make out with respect to the determination of how many of these petitioners are members in good standing? In March of 1997, Donohue, who owns property in the Development and is a member of the Association, circulated a Petition for the Call of a Special Meeting Arrowhead Lake Community Association (Petition). 22 reviews of Arrowhead Lake Community Association "We are home owners who vacation at Arrowhead. Looking to buy or sell a boat? xT0}+>hiQB"{KeF@33gLzuhYU9vde]g>77C/6=l[}ggot/IX #z[cx]=]u2M `s/x]":t A,gc)Rg4+eI9G^>'a! We therefore conclude that this appeal is indeed frivolous. You're all set! DispositionJudgment; Judgment Type: Dismissal - Request for Dismissal; Comment; Comment: (REQUEST FOR DISMISSAL FILED- WITH PREJUDICE. A similar provision is contained in Section 5755(b) of the Nonprofit Corporation Law of 1988(Law), 15 Pa.C.S. A PDF link to the proposed bylaw changes is below, proposed language is in red. The registered office location is at 27324 Arrowhead Ln, Conifer, CO 80433. However, after the appeal was filed, the Association nevertheless scheduled the special meeting demanded by Donohue for December 14, 1997, and the meeting has been held. (FILED IN SAN BERNARDINO COUNTY SUPERIOR COURT ON 12/07/2021 SUBMITTED ATTACHED TO NOTICE OF REMOVAL #1 )(lh), NON-CONFORMED COPY OF ANSWER to Third Amended Complaint, filed by Defendant Arrowhead Lake Association. DocketCertificate of Assignment Received; Comment: CERTIFICATE OF ASSIGNMENT RECEIVED. The survey did not inform the members ofmaterial legal agreements and settlements pertaining to Association property or to lake rightsthat would impact members, it did not explain the potential costs and liabilities associated withnew rules and litigation, and it did not provide any legal and financial analysis. Learn more about FindLaws newsletters, including our terms of use and privacy policy. endstream endobj startxref Ochoa found that the Arrowhead Lake Associations 2020 bylaw change, which prevented short-term renters from using the lake or the areas reserve strips, is likely to be proved to violate the associations 1964 Settlement Agreement. We love this community. Finally, one place to get all the court documents we need. An evidentiary hearing was conducted on August 18, 1997, by Common Pleas and Donohue presented testimony and introduced documents into evidence; the Association presented no evidence. The Lake Arrowhead community & local economy benefits greatly from visitors & tourism. The special meeting was for the purpose of considering an amendment to the Arrowhead Lake Community Association Bylaws (Bylaws) that would divest the Association's Board of Directors of the power to approve significant expenditures of money. The Lake Arrowhead Property Owners Association (LAPOA) is committed to providing the highest level of community living with a beautiful, well-maintained, safe and neighborly environment for the common benefit and enjoyment of all property owners. 3. Under Section 5755 of the Law, to call a special meeting of a nonprofit corporation, it must only be shown that ten percent of the members entitled to cast votes demand such a meeting. DocketCivil Case Cover Sheet Filed; Comment: CIVIL CASE COVER SHEET FILED. In early 2022, San Bernardino County Judge Gilbert G. Ochoa granted the plaintiffs apreliminary injunction preventing the Association from enforcing the new bylaw and several of the other rules the Association promulgated, but allowing the Association various enforcementcapabilities. Hopkins said, referencing California's main environmental statute. lake arrowhead communities chamber of commerce, a non-profit corporation lake arrowhead, california Rain, snow, hail and wind: A historic,five-day storm brought powerful gusts and dumped a massive amount of precipitation on the greater Los Angeles area starting last Wednesday. We will email you He accused environmentalists of fighting against any development on the mountain, framing the battle over Sonrise in the Woods as a referendum on civil liberties. Hence, the argument goes, Donohue did not establish a prima facie case and, for that reason, the burden never shifted to the Association. STAGE, NOTICE OF RULING FILED BY ARROWHEAD LAKE ASSOCIATI, NOTICE OF SETTLEMENT OF ENTIRE ACTION FILED BY SAF, NOTICE OF ASSOCIATION OF COUNSEL ON THE COMPLAINT, SUBSTITUTION OF ATTORNEY FILED; SUBSTITUTING LAW, ANSWER FILED BY SAFECO INSURANCE COMPANY OF AMERIC, PROOF OF SERVICE OF SUMMONS AND COMP-PET ON SAFECO, STIPULATION AND ORDER RE- TO CONSOLIDATE CASES FIL, SUMMONS ISSUED ON CROSS-COMPLAINT OF ARROWHEAD LAK, CROSS-COMPLAINT FILED ON COMPLAINT (UNLIMITED) OF, NOTICE OF RELATED CASE FILED BY ARROWHEAD LAKE ASS, ANSWER FILED BY ARROWHEAD LAKE ASSOCIATION; PARTY, PROOF OF SUB-SERVICE OF SUMMONS AND COMP-PET AS TO, NOTICE OF RULING ON TRIAL SETTING CONFERENCE FILED, Cases involving other personal injury not classified elsewhere, 360, 1360, 2360, 2367, 3360, 3367, 4360, 4367, 5360, 5367, Legacy Minutes; Comment: OSC RE: DISMISSAL, Order to Show Cause Re: Dismissal; Original Type: Order to Show Cause Re: Dismissal; Hearing Time: 8:30 AM; Cancel Reason: Vacated; Comment: OSC RE: DISMISSAL, Notice of Return of Document(s); Comment: NOTICE OF RETURN OF DOCUMENT(S). On 08/29/2017 DAILY filed a Personal Injury - Other Personal Injury - Other Personal Injury - Other Personal Injury lawsuit against ARROWHEAD LAKE ASSOCIATION MF.This case was filed in San Bernardino County Superior Courts, San Bernardino District Courthouse Civil Division located in San Bernardino, California. If you do not agree with these terms, then do not use our website and/or services. Jury Demanded, filed by Plaintiffs Jackie McKinley, Vertical Web Ventures, Inc., Seline Karakaye, Christopher Lee. General liability insurance to cover third party bodily injury (slips and falls or injuries on the docks) and third party property damage. Thereafter, the Association filed an answer to the motion which, among other things, disputed the authenticity of the signatures on the Petitions, but raised no affirmative defenses in new matter. On June 6, 1997, Donohue initiated an action against the Association by filing a Praecipe for Writ of Summons in the Common Pleas Court. Arrowhead Lake Pocono Lake Real Estate & Homes For Sale 138 Agent listings 6 Other listings Sort: Homes for You 185 Selig Rd, Pocono Lake, PA 18347 LAKE NAOMI REAL ESTATE $189,000 2 bds 1 ba 1,292 sqft - House for sale 3D Tour 132 Kickapoo Dr, Pocono Lake, PA 18347 KELLER WILLIAMS - POCONO PINES $239,900 3 bds 2 ba 768 sqft - House for sale Year Built: 1966. Burnt Mill Beach Club 27910 Lakes Edge Road, 1964 Agreement between Arrowhead Woods Property Owners & Lake Arrowhead Development Co. Below please find list of ALA Board Member contacts where you can send a personalized letter regarding your concerns. Renting Homeowners - Arrowhead Lake Community Association Renting Your Home New ALCA STR Policy & Permit New ALCA Short-Term Rental (STR) and Long-Term Rental (LTR) Policies are now in effect. 2022-01-26, San Bernardino County Superior Courts | Property | 2,436 were here. [House Hearing, 117 Congress] [From the U.S. Government Publishing Office] H.R. We will email you when the process is complete. %%EOF He has established a prima facie case. Folks in Orange County are inclined to agree. Will you do the same? Related forms. endstream endobj 113 0 obj <>stream At one time, more than 90 short term renters from one member were given access to our lake and property. President Joe Biden talks about his nomination of Julie Su, left, to serve as the Secretary of Labor during an event in the East Room of the White House in Washington, Wednesday, March 1, 2023. (Subscribe to view) The Association has appealed the preliminary injunction, which is still pending. (SUBMITTED ATTACHED TO NOTICE OF REMOVAL #1 ) (lh), NON-CONFORMED THIRD AMENDED COMPLAINT against Defendants Arrowhead Lake Association, Gary Clifford, Does, Brian C. Hall, Eran Heissler, Alan B. Kaitz, Robert Mattison, Anthony Okeefe, Christopher Wilson amending Amended Complaint,, filed by Plaintiffs Jackie McKinley, Vertical Web Ventures, Inc., Seline Karakaye, Christopher Lee. 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