Case: EEOC v. Hannah Motors Company

Equal Employment Opportunity Commission v. Hannah Motors Company

Equal Employment Opportunity Commission v. Hannah Motors Company

Equal Employment Opportunity Commission v. Hannah Motors Company

Equal Employment Opportunity Commission v. Hannah Motors Company

Equal Employment Opportunity Commission v. Hannah Motors Company

Equal Employment Opportunity Commission v. Hannah Motors Company

Equal Employment Opportunity Commission v. Hannah Motors Company

Carly Knight, Frank Dobbin, Alexandra Kalev

COMPLAINT (Summons(es) issued) (Receipt # Fee Waived) (Attachments: # 1)(JAB, ) (Entered: 10/06/2003)

2 Civil Cover Sheet

View on PACER

ORDER REGARDING DISCOVERY AND DEPOSITIONS. Signed by Jean Boring, Deputy Clerk, as directed by Judge Ronald B. Leighton. (Nelson, Debbie) (Entered: 10/07/2003)

ORDER REGARDING INITIAL DISCLOSURES, JOINT STATUS REPORT AND EARLY SETTLEMENT. Joint Status Report due by 1/9/2004. Signed by Jean Boring, Deputy Clerk, as directed by Judge Ronald B. Leighton. (Nelson, Debbie) (Entered: 10/07/2003)

SERVICE OF SUMMONS and Complaint returned executed upon defendant Hannah Motors Company on 10/9/2003. (CAR, ) (Entered: 10/20/2003)

ANSWER and affirmative defenses to Complaint by Defendant Hannah Motors Company.(ECS, ) (Entered: 10/29/2003)

AFFIDAVIT OF SERVICE by Plaintiff Equal Employment Opportunity Commission re 2 Discovery and Depositions Order, 3 Joint Status Report Order. (ECS, ) (Entered: 11/05/2003)

MOTION to Intervene by Interested Parties Ann Morgan, Genny Smith. Noting Date 11/28/2003. (Attachments: # 1 Proposed Order)(ECS, ) (Entered: 11/17/2003)

2 Proposed Order

View on PACER

DECLARATION of Beth A. Bloom filed by Interested Parties Ann Morgan, Genny Smith re 7 MOTION to Intervene (ECS, ) (Entered: 11/17/2003)

AMENDED ANSWER to Complaint and affirmative defenses by Defendant Hannah Motors Company.(ECS, ) (Entered: 11/17/2003)

SUPPLEMENTAL DECLARATION of Beth A. Bloom re 7 MOTION to Intervene (Attachments: # 1 Proposed Order)(ECS, ) (Entered: 12/01/2003)

2 Proposed Order

View on PACER

ORDER granting 7 Motion to Intervene by Judge Ronald B. Leighton. (ECS, ) (Entered: 12/01/2003)

AFFIDAVIT OF SERVICE by Plaintiff Equal Employment Opportunity Commission re 2 Discovery and Depositions Order, 3 Joint Status Report Order. (ECS, ) (Entered: 12/08/2003)

Intervenor COMPLAINT, filed by Ann Morgan, Genny Smith.(ECS, ) (Entered: 12/09/2003)

JOINT STATUS REPORT AND DISCOVERY PLAN filed by all parties. Est. Trial Days: 7. (Blankenship, Scott) (Entered: 12/30/2003)

NOTICE of Unavailability of counsel Scott Crispin Greco Blankenship for Intervenor Plaintiffs Ann Morgan, Genny Smith from January 15, 2004 to February 27, 2004 (Blankenship, Scott) (Entered: 01/14/2004)

ANSWER to Intervenor Complaint by Defendant Hannah Motors Company.(Rickles, Stephen) (Entered: 01/16/2004)

INITIAL DISCLOSURES by Defendant Hannah Motors Company.(Rickles, Stephen) (Entered: 01/16/2004)

MINUTE ORDER SETTING TRIAL, PRETRIAL DATES AND ORDERING MEDIATION; Length of Trial: 6-7 DAYS. Jury Trial set for 2/22/2005 09:30 AM in Courtroom A before Hon. Ronald B. Leighton. Joinder of Parties due by 3/1/2004; Expert Witness Disclosure due by 8/26/2004; Discovery due by 10/25/2004; Motions due by 11/24/2004; 39.1 Settlement Report due by 1/30/2005. Motions in Limine due by 1/25/2005; Pretrial Order due by 2/5/2005; Pretrial Conference set for 2/11/2005 08:30 AM in Courtroom B before Hon. Ronald B. Leighton. Trial briefs to be submitted by 2/11/2005; Voir dire/jury instructions due by 2/11/2005;Signed by Jean Boring as authorized by Judge Ronald B. Leighton. (JAB, ) (Entered: 02/03/2004)

MOTION to Join Additional Party by Intervenor Plaintiffs. Noting Date 3/19/2004. (Attachments: # 1 Proposed Order)(ECS, ) (Entered: 03/02/2004)

2 Proposed Order

View on PACER

DECLARATION of Scott C.G. Blankenship filed by Intervenor Plaintiffs re 19 P's MOTION to Join Additional Party (ECS, ) (Entered: 03/02/2004)

REPLY to Response to Motion filed by Intervenor Plaintiffs Ann Morgan, Genny Smith re 19 MOTION to Amend Complaint to Join Additional Party (Barrett Bloom, Beth) (Entered: 03/18/2004)

ORDER granting 19 P's Motion to Amend by Judge Ronald B. Leighton. Pl's to file amended Complaint w/in5 business days of order.(ECS, ) (Entered: 03/19/2004)

AMENDED COMPLAINT FOR DAMAGES against defendant BRYAN LINDSAY, Hannah Motors Company, filed by Ann Morgan, Genny Smith.(Barrett Bloom, Beth) (Entered: 03/26/2004)

PRAECIPE FOR ISSUANCE OF A SUMMONS for the 23 Amended Complaint filed by Pltfs'. (CAR, ) (Entered: 04/13/2004)

NOTICE of Unavailability of counsel Scott Crispin Greco Blankenship for Intervenor Plaintiffs Ann Morgan, Genny Smith from April 19, 2004 to May 3, 2004 (Blankenship, Scott) Modified on 4/19/2004 to edit text (ECS, ). (Entered: 04/16/2004)

NOTICE of Appearance by attorney Douglas E Somers on behalf of Defendant Bryan Lindsay (ECS, ) (Entered: 04/26/2004)

AFFIDAVIT OF SERVICE OF DEPOSITION SUBPOENA upon Vancouver Ford served on 5/28/04, filed by Defendant Hannah Motors Company. (CAR, ) (Entered: 06/07/2004)

NOTICE of Unavailability of counsel Beth Barrett Bloom for Intervenor Plaintiffs June 29, 2004 to July 9, 2004 (Blankenship, Scott) Modified on 6/14/2004 to edit docket text (ECS, ). (Entered: 06/11/2004)

NOTICE of Unavailability of counsel Beth A Barrett Bloom for Intervenor Plaintiffs Ann Morgan, Genny Smith from June 29, 2004 to July 9, 2004 (Barrett Bloom, Beth) (Entered: 06/24/2004)

ANSWER to Amended Complaint by Bryan Lindsay.(Somers, Douglas) (Entered: 06/25/2004)

MOTION to Compel Discovery by Intervenor Plaintiffs Ann Morgan, Genny Smith. Noting Date 9/10/2004. (Barrett Bloom, Beth) (Entered: 08/26/2004)

DECLARATION of Beth Barrett Bloom filed by Intervenor Plaintiffs Ann Morgan, Genny Smith re 31 MOTION to Compel Discovery (Attachments: #(1)Exhibit A1; #(2)Exhibit A2; #(3) Exhibit B-C)(Barrett Bloom, Beth) Modified on 8/27/2004; named attachments (CAR, ). (Entered: 08/26/2004)

2 Exhibit A1

View on PACER

3 Exhibit A2

View on PACER

4 Exhibit B-C

View on PACER

RESPONSE, by Defendant Hannah Motors Company, to 31 MOTION to Compel Discovery (Rickles, Stephen) (Entered: 09/03/2004)

AFFIDAVIT of Jennifer Hannah filed by Defendant Hannah Motors Company re 33 Response to Motion to Compel Discovery (Rickles, Stephen) (Entered: 09/03/2004)

AFFIDAVIT of Stephen P. Rickles filed by Defendant Hannah Motors Company re 33 Response to Motion to Compel Discovery (Attachments: # 1 Exhibit# 2 Exhibit# 3 Exhibit# 4 Exhibit# 5 Exhibit# 6 Exhibit# 7 Exhibit# 8 Exhibit# 9 Exhibit)(Rickles, Stephen) Modified on 9/7/2004; named attachments (AF, ). (Entered: 09/03/2004)

2 Exhibit

View on PACER

3 Exhibit

View on PACER

4 Exhibit

View on PACER

5 Exhibit

View on PACER

6 Exhibit

View on PACER

7 Exhibit

View on PACER

8 Exhibit

View on PACER

9 Exhibit

View on PACER

10 Exhibit

View on PACER

REPLY, filed by Intervenor Plaintiff Ann Morgan, TO RESPONSE to 31 MOTION to Compel Discovery (Blankenship, Scott) (Entered: 09/09/2004)

Supplemental DECLARATION of Beth Barrett Bloom filed by Intervenor Plaintiff Ann Morgan re 33 Response to Motion (Blankenship, Scott) (Entered: 09/09/2004)

Supplemental DECLARATION of Beth Barrett Bloom filed by Intervenor Plaintiff Ann Morgan re 31 MOTION to Compel Discovery (Attachments: # 1 Exhs A-C)(Blankenship, Scott) Modified on 9/10/2004 to describe attachment (ECS, ). (Entered: 09/09/2004)

2 Exhs A-C

View on PACER

ORDER granting 31 Plaintiff-Intervenors' Motion to Compel Discovery, signed by Judge Ronald B. Leighton.(DN, ) (Entered: 09/22/2004)

MINUTE ENTRY for proceedings held before Judge Ronald B. Leighton - Law Clerk: Greg Leever; CR: none; Time of Hearing: 2:30 to 2:50; Pla Counsel: Wes Katahira (EEOC); Scott Blankenship/Beth Bloom (Morgan & Smith); Def Counsel: Steve Rickles (H Motors)/Doug Somers (Lindsay); Telephone Conference held on 9/23/2004. Conf call occurred at request of D' Hannan by Mr. Rickels re: Having P' Morgan Examined by Psychiatrist of D's Choice based upon submission of expert report by Examing Psychiatrist on Behalf of P'. Argument: Court Orders that P' Morgan be examined by Psychiatrist of the D's Choice. Exam to happen ASAP & Report to follow within one week of examination. Discovery cut-off is extended for the sole purposed of allowing P to Depose D's Doctor. (JAB, ) Modified on 10/4/2004 (corrected spelling of attorney's name) (JAB, ). (Entered: 09/28/2004)

STIPULATION and Proposed Protective Order by parties. (Barrett Bloom, Beth) Modified on 9/30/2004; text edited (CAR, ). (Entered: 09/29/2004)

ORDER on STIPULATION 41 and PROTECTIVE ORDER; signed by Judge Ronald B. Leighton. (DN, ) (Entered: 10/04/2004)

AFFIDAVIT OF SERVICE OF DEPOSITION SUBPOENA upon Damerow Beaverton Ford, Records Custodian served on 10/12/04, filed by Defendant Hannah Motors Company. (CAR, ) (Entered: 10/22/2004)

AFFIDAVIT OF SERVICE OF DEPOSITION SUBPOENA upon Rabih Hourani, Damerow of Beaverton Ford served on 10/8/04, filed by Defendant Hannah Motors Company. (CAR, ) (Entered: 10/26/2004)

Joint MOTION and PROPOSED ORDER for Discovery (Limited Extension) Modification of the Scheduling Order and Resetting the Trial Date by Intervenor Plaintiff Ann Morgan. Noting Date 10/21/2004. (Barrett Bloom, Beth) Modified on 10/22/2004; text edited (CAR, ). (Entered: 10/21/2004)

AMENDED MINUTE ORDER SETTING TRIAL, PRETRIAL DATES AND ORDERING MEDIATION; Length of Trial: 6-7 DAYS. JURY TRIAL is reset for 5/9/2005 09:30 AM in Courtroom B before Hon. Ronald B. Leighton. Expert Witness Disclosure due by 11/10/2004; Discovery due by 3/10/2005; Motions due by 3/15/2005; 39.1 Settlement Report due by 4/15/2005; Motions in Limine due by 4/20/2005; Pretrial Order due by 4/22/2005; Pretrial Conference set for 4/29/2005 08:30 AM in Courtroom B before Hon. Ronald B. Leighton. Trial briefs to be submitted by 4/29/2005; Voir dire/jury instructions due by 4/29/2005; s/Jean Boring as directed by Judge Ronald B. Leighton. (JAB, ) (Entered: 10/25/2004)

DISCLOSURE OF EXPERT WITNESSES by Defendant Hannah Motors Company. (Attachments: # 1Exhibit A; # 2Exhibit B)(Rickles, Stephen) Modified on 11/12/2004; attachments named (CAR, ). (Entered: 11/10/2004)

2 Exhibit A

View on PACER

3 Exhibit B

View on PACER

NOTICE of Unavailability of counsel Beth A Barrett Bloom for Intervenor Plaintiffs Ann Morgan, Genny Smith from 12/20/04 to 12/31/04 (Barrett Bloom, Beth) (Entered: 12/16/2004)

MOTION to Compel Electronic Discovery by Intervenor Plaintiff Ann Morgan. Noting Date 2/25/2005. (Attachments: # 1 Proposed Order)(Blankenship, Scott) (Entered: 02/10/2005)

2 Proposed Order

View on PACER

DECLARATION of Beth Bloom filed by Intervenor Plaintiff Ann Morgan re 49 MOTION to Compel Electronic Discovery (Attachments: # 1 Exhibits A-G# 2 Exhibits H-M)(Blankenship, Scott) (Entered: 02/10/2005)

2 Exhibits A-G

View on PACER

3 Exhibits H-M

View on PACER

STIPULATION AND PROPOSED ORDER for Limited Extension of Discovery Deadline by parties. (Barrett Bloom, Beth) (Entered: 02/15/2005)

ORDER on STIPULATION 51 for extension of discovery deadline. Discovery due by 3/15/2005; signed by Judge Ronald B. Leighton. (DN, ) (Entered: 02/16/2005)

MOTION to Compel by Plaintiff Equal Employment Opportunity Commission. Noting Date 3/4/2005. (Katahira, Wesley) (Entered: 02/17/2005)

DECLARATION of Wesley Katahira filed by Plaintiff Equal Employment Opportunity Commission re 53 MOTION to Compel (Attachments: # 1 Exhibit Defendant's Answers to EEOC's First Set of Discovery)(Katahira, Wesley) (Entered: 02/17/2005)

2 Exhibit Defendant's Answers to EEOC's First Set of Discovery

View on PACER

NOTICE of Unavailability of counsel Scott Crispin Greco Blankenship for Intervenor Plaintiff Ann Morgan from 2/22/05 to 3/4/05 (Blankenship, Scott) (Entered: 02/18/2005)

MINUTE ORDER SETTING DEADLINE and STRIKING MOTIONS: Counsel has advised the Court that this matter has SETTLED; The Dismissal/Settlement papers should be submitted by 4/8/2005. The pending 53 MOTION to Compel filed by Equal Employment Opportunity Commission, and 49 MOTION to Compel Electronic Discovery filed by Ann Morgan are DENIED as Moot. If additional time is needed, Counsel should call Jean Boring, CRD to Judge Leighton, at 253-593-6581. s/Jean Boring as authorized by Judge Ronald B. Leighton. (JAB, ) (Entered: 02/22/2005)

REPORT from Mediator Michele M. Sales regarding success of mediation on 2/21/05. (CAR, ) (Entered: 03/02/2005)

NOTICE OF WITHDRAWAL OF COUNSEL: Attorney Beth A Barrett Bloom for Intervenor Plaintiffs Ann Morgan, Genny Smith. (Barrett Bloom, Beth) (Entered: 03/10/2005)

NOTICE by Plaintiff Equal Employment Opportunity Commission of Consent Decree (Proposed) (Katahira, Wesley) (Entered: 03/28/2005)

CONSENT DECREE, approved per Order of 3/30/05, by Judge Ronald B. Leighton. (DN, ) (Entered: 03/31/2005)

ORDER APPROVING Consent Decree 59 dismissing this matter with prejudice and without costs, signed by Judge Ronald B. Leighton. (DN, ) (Entered: 03/30/2005)