Case: EEOC v. HILL BOREN, P.C.

EEOC v. Hill Boren, P.C.

EEOC v. Hill Boren, P.C.

EEOC v. Hill Boren, P.C.

EEOC v. Hill Boren, P.C.

EEOC v. Hill Boren, P.C.

Carly Knight, Frank Dobbin, Alexandra Kalev

COMPLAINT FOR UNLAWFUL EMPLOYMENT PRACTICES PURSUANT TO TITLE VII OF THE CIVIL RIGHTS ACT OF 1964 against Hill Boren, P.C., filed by Equal Employment Opportunity Commission.(fsh, ) (Entered: 08/24/2005)

ANSWER to Complaint by Hill Boren, P.C..(jae, ) (Entered: 10/28/2005)

SETTING LETTER: Scheduling Conference set for 12/15/2005 10:30 AM in Courtroom 6 - Memphis before Tu M. Pham. (jae, ) (Entered: 11/10/2005)

SCHEDULING ORDER: Ititial disclosures due 1/3/06. Amended Pleadings due by 12/30/2005 (pla) 1/30/06(dft). Discovery due by 8/18/2006. Joinder of Parties due by 12/30/2005(pla) 1/30/06 (dft). Initial Motions to dismiss due by 1/17/2006. Dispositive m otions due 9/19/06. Case set for jury trial (4-days). Pretrial order, pretrial conference and trial dates will be set by the presiding judge. Parties are directed to engage in mediation on or before close of discovery. Parties have not consented to trial before the magistrate judge. Absent good cause shown, dates set by this order will not be modified or extended. Signed by Judge Tu M. Pham. (jae, )

ORDER SETTING TRIAL AND PRETRIAL DATES. Pretrial Order due by 11/13/2006. Jury Trial set for 11/27/2006 09:30 AM in Courtroom 4 - Memphis before Jon Phipps McCalla. Pretrial Conference set for 11/20/2006 09:00 AM in Courtroom 4 - Memphis before Jon Phipps McCalla. Absent good cause shown, dates set by this order will not be modified or extended. Signed by Judge Jon Phipps McCalla. (jae, )

SETTING LETTER: Jury Trial set for 11/27/2006 09:30 AM in Courtroom 4 - Memphis before Jon Phipps McCalla. Pretrial Conference set for 11/20/2006 09:00 AM in Courtroom 4 - Memphis before Jon Phipps McCalla. Proposed Joint Pretrial Order due 11/13/06.(jae, ) (Entered: 12/30/2005)

Set/Reset Deadlines: Proposed Pretrial Order due by 11/13/2006. (jae, )

MOTION to Intervene proposed order submitted by Rebekah Womack Petrowski. (Attachments: # 1 Memorandum Memorandum in Support of Motion to Intervene# 2 Certificate of Consultation Womack Certificate of Consultation)(Stevenson, David) (Entered: 02/10/2006)

ORDER granting 7 Motion to Intervene . Signed by Judge Jon Phipps McCalla on 2/15/06. (McCalla, Jon)

MOTION for Discovery Extension of Time to Respond to Plaintiff's Discovery Requests by Hill Boren, P.C.. (Hodges, Melissa) (Entered: 03/20/2006)

ORDER granting 9 Defendant's Motion for Extension of Time to Respond to Discovery Responses. Defendant shall have up to and including 3/30/06 to serve its responses to Ptf's First Request for Production of Docs and First Set of Interrogatories. Signed by Judge Tu M. Pham on 3/21/06. (Pham, Tu) (Entered: 03/21/2006)

COMPLAINT Western division Rebekah Womack Petrowski v. Hill Boren P.C.. (Attachments: # 1 Exhibit Order by Judge McCalla)(Stevenson, David) (Entered: 03/23/2006)

DEFICIENCY NOTICE: Pursuant to Rule 5 of the Federal Rules of Civil Procedure, document 11 Complaint has been filed. However, the following deficiency has been found: The Pleading was not titled correctly.Per phone conversation filer will resubmit with "Intervenor Complaint" as the title. The filer has one business day to correct the deficiency. (fsh) (Entered: 03/23/2006)

Intervenors COMPLAINT Western division Rebekah Womack Petrowski v. Hill Boren P.C.. (Attachments: # 1 Exhibit Order Granting Motion to Intervene)(Stevenson, David) Modified on 3/23/2006 to edit text (fsh). (Entered: 03/23/2006)

MOTION to Substitute Attorney (Proposed Order submitted) by Equal Employment Opportunity Commission. (Rapport, Adele) (Entered: 03/28/2006)

MOTION to Substitute Attorney [This is to correct previous submission with incorrect Judge assignation] (Proposed Order submitted) by Equal Employment Opportunity Commission. (Rapport, Adele) (Entered: 03/28/2006)

ORDER granting 15 Motion to Substitute Attorney. Signed by Judge Jon Phipps McCalla on 3/31/06. (McCalla, Jon)[No written order attached] (Entered: 03/31/2006)

Answer to Intervenor's Complaint 13 with Jury Demand by Hill Boren, P.C..(Hodges, Melissa) Modified on 4/11/2006 to add docket relationship (jae, ) (Entered: 04/11/2006)

MOTION for Extension of Time to Complete Discovery Deadline for Designation of Expert Witness by Hill Boren, P.C.. (Attachments: # 1 Memorandum In Support of Motion for Extention of Deadline for Designation of Expert)(Hodges, Melissa) (Entered: 05/19/2006)

COURTESY NOTICE: Pursuant to Rule 5 of the Federal Rules of Civil Procedure, document 18 MOTION for Extension of Time to Complete Discovery Deadline for Designation of Expert Witness filed by Hill Boren, P.C., has been filed. For future reference, please note Filer did not indicate (proposed order submitted) as required by Local Rule 7.2 (1)(A). Please submit proposed order to chambers. Filer is not required to resubmit document. (jae, ) (Entered: 05/22/2006)

RESPONSE to Motion re 18 MOTION for Extension of Time to Complete Discovery Deadline for Designation of Expert Witness filed by Equal Employment Opportunity Commission. (Smith, Deidre) (Entered: 06/02/2006)

ORDER GRANTING DEFENDANT'S MOTION FOR EXTENTION OF DEADLINE FOR DESIGNATION OF EXPERT WITNESSES re 18 ...For good cause shown, the motion is GRANTED. Defendant shall have until June 20, 2006, to disclose expert witnesses. Plaintiff shall have 30 days from the date of defendant's expert disclosures to disclose plaintiff's rebuttal expert, if any. All other dates in the scheduling order, including the trial date, shall remain the same. It is so ordered. Signed by Judge Tu M. Pham on 6/20/06. (wmw, ) (Entered: 06/20/2006)

MOTION for Extension of Time to Complete Discovery Extension of Deadline for Designation of Expert Witnesses by Hill Boren, P.C.. (Attachments: # 1 Memorandum Memorandum re Defendant's Motion for Extension of Deadline for Designation of Expert Witness)(Hodges, Melissa) (Entered: 06/30/2006)

COURTESY NOTICE: Pursuant to Rule 5 of the Federal Rules of Civil Procedure, document 22 MOTION for Extension of Time to Complete Discovery Extension of Deadline for Designation of Expert Witnesses filed by Hill Boren, P.C., has been filed. For future reference, please note : Filer did not indicate if a proposed order was submitted to chambers. Filer is not required to resubmit document unless no order was submitted via email. (jae, ) (Entered: 07/03/2006)

ORDER denying 22 Without Prejudice Defendant's Motion for Extension of Deadline for Designation of Expert Witnesses. Signed by Judge Tu M. Pham on 7/6/06. (Pham, Tu) (Entered: 07/06/2006)

MOTION to Substitute Attorney Proposed Order Submitted, MOTION to Withdraw as Attorney Proposed Order Submitted by Equal Employment Opportunity Commission. (Smith, Deidre) (Entered: 07/31/2006)

ORDER granting 25 Plaintiff EEOC's Motion to Withdraw & Substitute Attorney. Adele Rapport GRANTED leave to withdraw as counsel and Fay Williams substituted as counsel . Signed by Judge Tu M. Pham on 7/31/06. (Pham, Tu) (Entered: 07/31/2006)

Joint MOTION for Extension of Time to Complete Discovery and Resetting of Trial Date, proposed order submitted by Hill Boren, P.C.. (Attachments: # 1Memorandum In Support )(Hodges, Melissa) Modified on 8/1/2006 to add description to attachment (jae, ). (Entered: 07/31/2006)

MOTION to Compel Discovery by Hill Boren, P.C.. (Attachments: # 1 Memorandum Supporting Defendant's Motion to Compel Discovery# 2 Exhibit A - June 16, 2006 Letter to Norwood# 3 Exhibit B - August 3, 2006 Letter to Norwood# 4 Exhibit C - June 30, 2006 Letter to Norwood)(Hodges, Melissa) (Entered: 08/10/2006)

COURTESY NOTICE: Pursuant to Rule 5 of the Federal Rules of Civil Procedure, document 28 MOTION to Compel Discovery filed by Hill Boren, P.C., has been filed. For future reference, please note : Filer did not indicate if a proposed order was submitted to chambers. Filer is not required to resubmit document, but must sumbit proposed order. (jae, ) (Entered: 08/11/2006)

ORDER SETTING SCHEDULING CONFERENCE. Signed by Judge Jon Phipps McCalla on 8/14/06. (McCalla, Jon) (Entered: 08/14/2006)

SETTING LETTER: Scheduling Conference set for 8/28/2006 08:45 AM in Courtroom 4 - Memphis before Jon Phipps McCalla. (jpw) (Entered: 08/15/2006)

*CORRECTED SETTING LETTER: Scheduling Conference *VIA TELEPHONE set for 8/28/2006 08:45 AM in Chambers before Jon Phipps McCalla. (jpw) (Entered: 08/15/2006)

RESPONSE to Motion re 28 MOTION to Compel Discovery proposed order submitted filed by Rebekah Womack Petrowski. (Stevenson, David) (Entered: 08/23/2006)

ORDER finding as moot 28 Defendant's Motion to Compel. Signed by Judge Tu M. Pham on 8/28/06. (Pham, Tu) (Entered: 08/28/2006)

Minute Entry for proceedings held before Judge Jon Phipps McCalla: Scheduling Conference held on 8/28/2006. Discovery to be completed by 11/20/2006. Jury Trial reset to 3/19/2007 at 9:30 AM. Pretrial Conference reset to 3/13/2007 at 9:00 AM. Pretrial Order due by 4:30 PM on 3/6/2007. The Court will allow the examination of the Plaintiff with no attorneys present. Defendant's expert disclosure: 9/29/2006. Plaintiff's expert disclosure: 10/30/2006. Complaint to be amended within 10 days. Response due 5 days thereafter. (EEOC: Deidre Smith) (Petrowski: Dan Norwood, David Stevenson) (Hill-Boren: Thomas Henderson, Melissa Kimberly Hodges) (Court Reporter: Brenda Parker) (jpw) (Entered: 08/28/2006)

SETTING LETTER: Jury Trial set for 3/19/2007 09:30 AM in Courtroom 4 - Memphis before Jon Phipps McCalla. Pretrial Conference set for 3/13/2007 09:00 AM in Courtroom 4 - Memphis before Jon Phipps McCalla. Pretrial Order due by 4:30 PM on 3/6/2007.(jpw) (Entered: 08/28/2006)

Set Deadlines/Hearings: Proposed Joint Pretrial Order due by 4:30 PM on 3/6/2007. (jpw)

ORDER FOLLOWING STATUS CONFERENCE AND SETTING SCHEDULE. Signed by Judge Jon Phipps McCalla on 8/28/06. (McCalla, Jon) (Entered: 08/29/2006)

Set Deadlines/Hearings: Discovery due by 11/20/2006. Motions due by 12/22/2006. Pretrial Order due by 3/6/2007. Jury Trial set for 3/19/2007 09:30 AM in Courtroom 4 - Memphis before Jon Phipps McCalla. Pretrial Conference set for 3/13/2007 09:00 AM in Courtroom 4 - Memphis before Jon Phipps McCalla. (jae, )

MOTION to Amend/Correct 1 Complaint (Proposed Order Submitted) by Equal Employment Opportunity Commission. (Attachments: # 1 Memorandum in Support of Motion to Amend Complaint# 2 Certificate of Consultation # 3 Exhibit Amended Complaint)(Smith, Deidre) (Entered: 09/07/2006)

ORDER granting 38 Plaintiff EEOC's Motion for Leave to File Amended Complaint. Plaintiff shall file its amended complaint w/i 7 days from the date of this order with service upon the parties. Signed by Judge Tu M. Pham on 9/8/06. (Pham, Tu) (Entered: 09/08/2006)

AMENDED COMPLAINT against Hill Boren, P.C., filed by Equal Employment Opportunity Commission. (Smith, Deidre) (Entered: 09/08/2006)

COURTESY NOTICE: Pursuant to Rule 5 of the Federal Rules of Civil Procedure, document 40 Amended Complaint filed by Equal Employment Opportunity Commission, has been filed. For future reference, please note: Filer should have sent the amended complaint to chambers with the proposed order, not submitted it to the docket as an attachment to the motion. Filer is not required to resubmit document. (jae, ) (Entered: 09/08/2006)

ANSWER to Amended Complaint by Hill Boren, P.C..(Hodges, Melissa) (Entered: 09/15/2006)

MOTION for Extension of Time to Complete Discovery re Expert Designation; proposed order submitted by Hill Boren, P.C.. (Attachments: # 1 Memorandum)(Hodges, Melissa) (Entered: 09/29/2006)

ORDER Granting 43 Defendant's Unopposed Motion for Extension of Deadline for Designation of Expert Witnesses. Defendants shall have up to and including 11/3/06 to designate an expert witnesses. All other dates and deadlines, including the deadline for filing dispositive motions and the trial date, shall remain the same. Signed by Judge Tu M. Pham on 10/4/06. (Pham, Tu) (Entered: 10/04/2006)

Joint MOTION for Extension of Time to Complete Discovery and Resetting of Trial Date, Proposed Order Submitted by Equal Employment Opportunity Commission, Rebekah Womack Petrowski, Hill Boren, P.C.. (Attachments: # 1 Memorandum in Support of Joint Motion)(Hodges, Melissa) (Entered: 11/03/2006)

SETTING LETTER: Telephone Conference set for 11/17/2006 09:00 AM in Courtroom 4 - Memphis before Jon Phipps McCalla. (jpw) (Entered: 11/09/2006)

ORDER granting 45 Motion for Extension of Time to Complete Discovery . Signed by Judge Jon Phipps McCalla on 11/15/06. (McCalla, Jon) (Entered: 11/16/2006)

Minute Entry for proceedings held before Judge Jon Phipps McCalla: Telephone Conference held on 11/17/2006 to set new trial & pretrial dates. Jury Trial reset to 9/17/2007 at 9:30 AM. Pretrial Conference reset to 9/10/2007 at 9:00 AM. Pretrial Order due by 4:30 PM on 9/4/2007. (Plaintiff EEOC: Deidre Smith) (Intervenor Plaintiff: Dan Norwood) (Defense: Thomas Henderson) (Court Reporter: Brenda Parker) (jpw) (Entered: 11/17/2006)

SETTING LETTER: Jury Trial reset for 9/17/2007 09:30 AM in Courtroom 4 - Memphis before Jon Phipps McCalla. Pretrial Conference reset for 9/10/2007 09:00 AM in Courtroom 4 - Memphis before Jon Phipps McCalla. Pretrial Order due by 4:30 PM on 9/4/2007.(jpw) (Entered: 11/17/2006)

Set Deadlines: Proposed Pretrial Order due by 4:30 PM on 9/4/2007. (jpw)

ORDER RE-SETTING TRIAL AND PRETRIAL DATES. Signed by Judge Jon Phipps McCalla on 11/21/06. (McCalla, Jon) (Entered: 11/22/2006)

Set Deadlines/Hearings: Pretrial Order due by 9/4/2007. Jury Trial set for 9/17/2007 09:30 AM before Jon Phipps McCalla. Pretrial Conference set for 9/10/2007 09:00 AM before Jon Phipps McCalla. (jae, )

Joint MOTION for Extension of Time to Complete Discovery and Resetting of Trial Date (Proposed Order submitted) by Equal Employment Opportunity Commission. (Attachments: # 1 Memorandum in Support of Motion to Modify Scheduling Order)(Smith, Deidre) (Entered: 05/16/2007)

MOTION to Compel (Proposed Order submitted) by Equal Employment Opportunity Commission. (Attachments: # 1 Memorandum in Support of Motion to Compel# 2 Exhibit No. 1, Plaintiff's First Set of Interrogatories# 3 Exhibit No. 2, Plaintiff's First Request for Production# 4 Exhibit No. 3a, Defendant's Responses to Plaintiff's First Request for Production# 5 Exhibit No. 3b, Defendant's Responses to Plaintiff's First Set of Interrogatories# 6 Exhibit No. 4, 6-16-06 Smith Letter to Tom Henderson# 7 Exhibit No. 5, 7-7-06 Email from Kim Hodges# 8 Exhibit No. 6, 10-24-06 Smith Letter to Kim Hodges# 9 Exhibit No. 7, 10-25-06 Email to Kim Hodges# 10 Exhibit No. 8, 3-2-07 Email to Tom Henderson# 11 Exhibit No. 9, 4-10-07 Smith Letter to Tom Henderson# 12 Exhibit No. 10, 5-9-07 Smith Letter to Tom Henderson# 13 Exhibit No. 11, 5-10-06 Henderson Letter to Deidre Smith# 14 Exhibit No. 12, Charge of Discrimination# 15 Exhibit No. 13, 2-3-06 Henderson Letter to Deidre Smith# 16 Exhibit No. 14, 2-8-06 Smith Letter to Tom Henderson# 17 Exhibit No. 15, 2-28-06 Email to Kim Hodges# 18 Exhibit No. 16, 7-16-06 Notice of Deposition to Robert Hill# 19 Exhibit No. 17, 6-30-06 Email from Kim Hodges# 20 Exhibit No. 18, 7-11-06 Smith Letter to Kim Hodges# 21 Exhibit No. 19, 7-28-06 Smith Email to Kim Hodges# 22 Exhibit No. 20, 8-11-06 Amended Notice of Deposition to Robert Hill# 23 Errata No. 21, 8-23-06 Smith Email to Kim Hodges# 24 Errata No. 22, 10-16-06 Smith Email to Kim Hodges# 25 Exhibit No. 23, 11-1-06 Notice of Deposition for Robert Hill# 26 Exhibit No. 24, 5-9-07 Notice of Deposition of Robert Hill# 27 Exhibit No. 25, 5-9-06 Henderson Letter to Deidre Smith# 28 Exhibit No. 26, 5-11-07 Smith Letter to Tom Henderson# 29 Errata No. 27, 5-17-07 Smith Letter to Tom Henderson# 30 Unreported Case - International Brotherhood of Electrical Workers v. Eagle Electric Co..pdf# 31 Unreported Case - Jones v. Simon & Schuster, Inc..pdf# 32 Unreported Case - Kelly v. Williams.pdf# 33 Unreported Case - Willis v. Golden Rule Ins. Co..pdf# 34 Certificate of Consultation)(Smith, Deidre) (Entered: 05/22/2007)

ORDER 51 JOINT MOTION TO MODIFY FED. R. CIV. P. 16(b) SCHEDULING ORDER; ORDER RESETTING TRIAL AND PRETRIAL DATES . Signed by Judge Jon Phipps McCalla on 5/25/07. (McCalla, Jon) (Entered: 05/24/2007)

SETTING LETTER: Jury Trial reset for 1/7/2008 09:30 AM in Courtroom 4 - Memphis before Judge Jon Phipps McCalla. Pretrial Conference reset for 1/2/2008 09:00 AM in Courtroom 4 - Memphis before Judge Jon Phipps McCalla. Pretrial Order due by 4:30 PM on 12/*26/2007.(jpw) *Modified on 5/25/2007 (jpw). (Entered: 05/24/2007)

Set Deadline: Proposed Pretrial Order due by 4:30 PM on 12/26/2007. (jpw)

Consent MOTION for Extension of Time to File Response/Reply as to 52 MOTION to Compel (Proposed Order submitted) (Proposed Order Submitted) by Hill Boren, P.C.. (Gunn, Kristy) (Entered: 06/06/2007)

ORDER Granting 55 Defendant's Unopposed Motion for Extension of Time to Respond to EEOC's Motion to Compel. Defendant shall have up to and including 6/21/07 to respond to EEOC's motion. Signed by Magistrate Judge Tu M. Pham on 6/7/07. (Pham, Tu) (Entered: 06/07/2007)

RESPONSE in Opposition re 52 MOTION to Compel (Proposed Order submitted) filed by Hill Boren, P.C.. (Attachments: # 1 Exhibit EEOC 6-13-07 Letter# 2 Exhibit EEOC 6-20-07 Letter# 3 Exhibit EEOC Complaint# 4 Exhibit Intervenor Complaint# 5 Exhibit Unreported Cases)(Gunn, Kristy) (Entered: 06/21/2007)

NOTICE by Hill Boren, P.C. of Change of Association (Gunn, Kristy) (Entered: 07/03/2007)

NOTICE of Hearing on Motion 52 Motion to Compel: Telephonic Hearing set for 7/12/2007 @ 10:30 AM (cst) - Memphis before Magistrate Judge Tu M. Pham. (wmw, ) (Entered: 07/05/2007)

Minute Entry for proceedings held before Magistrate Judge Tu M. Pham on 7/12/2007 : Telephonic Hearing held on EEOC's motion to compel 52 . The court granted the motion. Order to be entered. Plt cnsl: D. Smith. Dft cnsl: T. Henderson. Intv/Plt cnsl: D. Norwood (Tape #FTR.) (wmw, ) (Entered: 07/12/2007)

ORDER re 52 Following Hearing Granting Plaintiff's MOTION to Compel filed by Equal Employment Opportunity Commission. Plaintiff shall provide the defendant with a proposed protective order for review, and once approved by defendant, shall submit the protective order to the Magistrate Judge for review and approval. The defendant shall then produce within seven (7) business days from the entry tof the protective order information and documents responsive to Interrogatory #11 and document request #18. Signed by Magistrate Judge Tu M. Pham on 7/12/07. (Pham, Tu) (Entered: 07/12/2007)

MOTION for Protective Order (Proposed Order Submitted) by Hill Boren, P.C.. (Attachments: # 1 Memorandum # 2 Exhibit Petrowski Depo# 3 Exhibit Wade Depo# 4 Exhibit Cases)(Henderson, Thomas) (Entered: 07/13/2007)

ORDER REFERRING MOTION: 62 Defendant's Motion for Protective Order. Signed by Judge Jon Phipps McCalla on 7/16/07. (McCalla, Jon) (Entered: 07/16/2007)

SETTLEMENT AGREEMENT AND ORDER. Signed by Judge Jon Phipps McCalla on 7/23/07. (Attachments: # 1 Appendix A - Harassment # 2 Appendix B Notice)(McCalla, Jon) (Entered: 07/23/2007)

JUDGMENT . Signed by Judge Jon Phipps McCalla on 7/23/07. (McCalla, Jon) (Entered: 07/23/2007)