Case: EEOC v. TeleServices Marketing Corporation

EEOC v. Teleservices Marketing Corporation

EEOC v. Teleservices Marketing Corporation

EEOC v. Teleservices Marketing Corporation and General Telemarketing International, Inc.

EEOC v. Teleservices Marketing Corporation

EEOC v. Teleservices Marketing Corporation

EEOC v. Teleservices Marketing Corporation and General Telemarketing International, Inc.

EEOC v. Teleservices Marketing Corporation

Carly Knight, Frank Dobbin, Alexandra Kalev

Case transferred in from Northern District of Texas Dallas Div; Case Number 3:03cv2227. Original file with documents numbered 1 - 12, certified copy of transfer order and docket sheet received, filed by Equal Employment Opportunity Commission.(ttm, ) (Entered: 03/05/2004)

Magistrate Consent Form and Notice of Case Assignment Mailed to Equal Employment Opportunity Commission, Teleservices Marketing Corporation (ttm, ) (Entered: 03/05/2004)

ORDER for Scheduling Conference set for 7/2/2004 10:00 AM in US Courthouse 101 E Pecan (Sherman) TX before Judge Paul N Brown.. Signed by Judge Paul N Brown on 6/7/04. cc:attys on 6/9/04(ttm, ) (Entered: 06/09/2004)

ACKNOWLEDGEMENT OF RECEIPT by atty Richard Wood for Teleservices Marketing Corporation as to 14 Order (ttm, ) (Entered: 06/18/2004)

MOTION to Continue Scheduling Conference by Equal Employment Opportunity Commission. (Attachments: # 1 Text of Proposed Order) (ttm, ) (Entered: 06/23/2004)

ORDER granting 16 Motion to Continue the Scheduling Conference until 7/28/04 at 1:30 pm. Signed by Judge Paul N Brown on 6/24/04. cc: attys 6/28/04 (baf, ) (Entered: 06/28/2004)

Set/Reset Trial Management Order Deadlines: Status Conference set for 7/28/2004 01:30 PM in Ctrm 208 (Sherman) before Judge Paul N Brown. (baf, ) (Entered: 06/28/2004)

ACKNOWLEDGEMENT OF RECEIPT as to 17 Order on Motion to Continue by Richard Wood. (baf, ) (Entered: 07/08/2004)

Minute Entry for proceedings held before Judge Paul N Brown : Scheduling Conference held on 7/28/2004. (snh, ) (Entered: 07/28/2004)

AMENDED COMPLAINT against Teleservices Marketing Corporation , filed by Teleservices Marketing Corporation.(ttm, ) (Entered: 09/01/2004)

MOTION to Amend/Correct by Equal Employment Opportunity Commission. (Attachments: # 1 Errata Amended Complaint# 2 Exhibit Deposition# 3 Exhibit Charge# 4 Exhibit E-Mails# 5 Exhibit Company Documents)(Mallon, Keri) (Entered: 09/30/2004)

RESPONSE to Motion re 21 MOTION to Amend/Correct the Complaint to Add Defendant filed by Teleservices Marketing Corporation. (Attachments: # 1 Affidavit Part 1# 2 Affidavit Part 2)(Weatherly, Grace) (Entered: 10/07/2004)

NOTICE of Change of Address by Grace Ann Weatherly (Weatherly, Grace) (Entered: 10/26/2004)

STIPULATION Designator of Mediator by Equal Employment Opportunity Commission. (Mallon, Keri) (Entered: 10/28/2004)

STIPULATION Designation of Mediator by Equal Employment Opportunity Commission. (Mallon, Keri) (Entered: 10/28/2004)

ORDER REFERRING CASE to Mediator. Courtenay Bass added as Mediator. Signed by Judge Paul N Brown on 10/29/04. Mediation conference shall be completedby December 31, 2004(sjs, ) (Entered: 10/29/2004)

REPORT of Mediation by Courtenay Bass. Mediation result: no settlement(Bass, Courtenay) (Entered: 11/29/2004)

REPORT of Mediation by Courtenay Bass. Mediation result: no settlement(Bass, Courtenay) (Entered: 11/29/2004)

MOTION to Quash Defendant's Deposition Upon Written Questions and Documents to be Produced by Equal Employment Opportunity Commission. (Attachments: # 1 Exhibit Subpoena# 2 Exhibit Subpoena) (Mallon, Keri) (Entered: 01/06/2005)

RESPONSE in Opposition re 29 MOTION to Quash Defendant's Deposition Upon Written Questions and Documents to be Produced filed by Teleservices Marketing Corporation. (Attachments: # 1 Affidavit of Donna Bradford)(Weatherly, Grace) (Entered: 01/21/2005)

MOTION to Compel Discovery by Equal Employment Opportunity Commission. (Attachments: # 1 Exhibit # 2 Exhibit # 3 Exhibit # 4 Exhibit # 5 Exhibit # 6 Exhibit # 7 Exhibit)(Mallon, Keri) (Entered: 01/31/2005)

MOTION to Compel Discovery Responses and Supporting Brief by Teleservices Marketing Corporation. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Text of Proposed Order Order on Defendant's Motion to Compel Discovery Responses)(Weatherly, Grace) (Entered: 02/04/2005)

ORDER re 29 MOTION to Quash Defendant's Deposition Upon Written Questions and Documents to be Produced filed by Equal Employment Opportunity Commission, which exceeds five pages in length. Plaintiff has not complied with the Court's rule that a written courtesy copy of all pleadings exceeding five pages in length should be furnished to the Court. This motion will not be considered by the Court unless, on or before ten days from the date of this order, Plaintiff furnishes the Court a written copy of said pleading. Signed by Judge Paul N Brown on 2/8/05. cc:attys on 2/8/05(ttm, ) (Entered: 02/08/2005)

RESPONSE in Opposition re 31 MOTION to Compel Discovery filed by Teleservices Marketing Corporation. (Weatherly, Grace) (Entered: 02/15/2005)

NOTICE of Attorney Appearance by Toby W Costas on behalf of Equal Employment Opportunity Commission (Costas, Toby) (Entered: 02/18/2005)

RESPONSE in Opposition re 32 MOTION to Compel Discovery Responses and Supporting Brief filed by Equal Employment Opportunity Commission. (Attachments: # 1 Exhibit # 2 Exhibit # 3 Exhibit # 4 Exhibit # 5 Exhibit # 6 Exhibit)(Mallon, Keri) (Entered: 02/24/2005)

ORDER granting 21 Motion to Amend the complaint to add defendant . Signed by Judge Paul N Brown on 3/1/05. cc:attys on 3/1/05 (ttm, ) (Entered: 03/01/2005)

AMENDED COMPLAINT against Teleservices Marketing Corporation, filed by Equal Employment Opportunity Commission.(Mallon, Keri) (Entered: 03/04/2005)

ORDER denying 29 Motion to Quash, granting 31 Motion to Compel and denying 32 Motion to Compel . Signed by Judge Paul N Brown on 3/15/05. cc:attys on 3/15/05 (ttm, ) (Entered: 03/15/2005)

Minute Entry for proceedings held before Judge Paul N Brown : Telephonic Motion Hearing held on 3/15/2005 re 31 MOTION to Compel Discovery filed by Equal Employment Opportunity Commission,, 32 MOTION to Compel Discovery Responses and Supporting Brief filed by Teleservices Marketing Corporation,, 29 MOTION to Quash Defendant's Deposition Upon Written Questions and Documents to be Produced filed by Equal Employment Opportunity Commission,. (snh, ) (Entered: 03/15/2005)

ANSWER to Amended Complaint by General Telemarketing International, Inc..(Weatherly, Grace) (Entered: 03/24/2005)

MOTION for Leave to File Second Amended Answer by Teleservices Marketing Corporation. (Attachments: # 1 Exhibit A)(Weatherly, Grace) Additional attachment(s) added on 3/24/2005 (ttm, ). (Entered: 03/24/2005)

***Document filed improperly, Proposed order is now attached to Motion #41*** Additional Attachments to Main Document: 41 MOTION for Leave to File Second Amended Answer .. (Weatherly, Grace) Modified on 3/24/2005 (ttm, ). (Entered: 03/24/2005)

***FILED IN ERROR. Document # 42, Proposed Order. PLEASE IGNORE. This order has been attached to Motion #41*** (ttm, ) (Entered: 03/24/2005)

MOTION for Summary Judgment by Teleservices Marketing Corporation. (Attachments: # 1 Exhibit A# 2 Exhibit B)(Weatherly, Grace) Additional attachment(s) added on 4/4/2005 (ttm, ). (Entered: 04/01/2005)

MOTION for Summary Judgment by General Telemarketing International, Inc.. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C)(Weatherly, Grace) Additional attachment(s) added on 4/4/2005 (ttm, ). (Entered: 04/01/2005)

NOTICE of Disclosure by General Telemarketing International, Inc. (Weatherly, Grace) (Entered: 04/01/2005)

ORDER granting 41 Motion for Leave to File Second Amended Answer. IT IS ORDERED ADJUDGED and DECREED that Dft Teleservices Marketing Corporation's Second Amended Answer be deemed filed as of the date of its receipt by the Clerk of the Court. Signed by Judge Paul N Brown on 04/13/05. (lhj, ) (Entered: 04/14/2005)

SECOND AMENDED ANSWER by Teleservices Marketing Corporation. (lhj, ) (Entered: 04/14/2005)

RESPONSE in Opposition re 44 MOTION for Summary Judgment filed by Equal Employment Opportunity Commission. (Attachments: # 1 Exhibit # 2 Exhibit # 3 # 4 Exhibit # 5 Exhibit # 6 Exhibit # 7 Exhibit # 8 Exhibit # 9 Exhibit)(Francis, Ronetta) (Entered: 04/18/2005)

***Deficient document, REPLACED BY DOCUMENT #50*** RESPONSE to Motion re 43 MOTION for Summary Judgment filed by Equal Employment Opportunity Commission. (Attachments: # 1 Exhibit # 2 Exhibit # 3 Exhibit # 4 Exhibit # 5 Exhibit # 6 Exhibit # 7 Exhibit) (Mallon, Keri) Modified on 4/20/2005 (ttm, ). (Entered: 04/18/2005)

RESPONSE in Opposition re 43 MOTION for Summary Judgment filed by Equal Employment Opportunity Commission. (Attachments: # 1 Exhibit # 2 Exhibit # 3 Exhibit # 4 Exhibit # 5 Exhibit # 6 Exhibit # 7 Exhibit)(Mallon, Keri) (Entered: 04/18/2005)

***FILED IN ERROR. PLEASE IGNORE Document # 49, Response to Motion for Summary Judgment. REPLACED BY DOCUMENT #50.*** (ttm, ) (Entered: 04/20/2005)

NOTICE of Attorney Appearance by Sherry Lynn Shipman on behalf of Teleservices Marketing Corporation, General Telemarketing International, Inc. (Shipman, Sherry) (Entered: 04/22/2005)

MOTION for Extension of Time to File Response/Reply in Support of Defendant's Motion for Summary Judgment by General Telemarketing International, Inc.. (Attachments: # 1 Text of Proposed Order) (Weatherly, Grace) (Entered: 04/28/2005)

MOTION for Extension of Time to File Response/Reply in Support of Defendant's Motion for Summary Judgment by Teleservices Marketing Corporation. (Attachments: # 1 Text of Proposed Order)(Weatherly, Grace) (Entered: 04/28/2005)

RESPONSE in Opposition re 52 MOTION for Extension of Time to File Response/Reply in Support of Defendant's Motion for Summary Judgment , 53 MOTION for Extension of Time to File Response/Reply in Support of Defendant's Motion for Summary Judgment filed by Equal Employment Opportunity Commission. (Mallon, Keri) (Entered: 04/29/2005)

ORDER granting 52 Motion for Extension of Time to File Response/Reply re 44 MOTION for Summary Judgment Replies due by 5/2/2005.. Signed by Judge Paul N Brown on 4/29/05. cc:attys on 4/29/05 (ttm, ) (Entered: 04/29/2005)

ORDER granting 53 Motion for Extension of Time to File Response/Reply re 43 MOTION for Summary Judgment Replies due by 5/2/2005.. Signed by Judge Paul N Brown on 4/29/05. cc:attys on 4/29/05 (ttm, ) (Entered: 04/29/2005)

REPLY to Response to Motion re 44 MOTION for Summary Judgment filed by General Telemarketing International, Inc.. (Weatherly, Grace) (Entered: 05/02/2005)

REPLY to Response to Motion re 43 MOTION for Summary Judgment filed by Teleservices Marketing Corporation. (Attachments: # 1 Affidavit Grace Weatherly)(Weatherly, Grace) (Entered: 05/02/2005)

RESPONSE to 58 Reply to Response to Motion #58 Surreply by Equal Employment Opportunity Commission. (Attachments: # 1 Exhibit Declaration of Shana Gentle)(Mallon, Keri) (Entered: 05/06/2005)

ORDER re 44 MOTION for Summary Judgment filed by General Telemarketing International, Inc.,. The Court will consider this motion as a motion for sum jgm and will decide the motion on or after 7/18/2005. Each party may submit any supplemental sum jgm evidence in support or in opposition to the motion that it desires the Court to consider on or before 7/18/2005. Signed by Judge Paul N Brown on 7/5/2005. (baf, ) (Entered: 07/05/2005)

NOTICE by Teleservices Marketing Corporation, General Telemarketing International, Inc. of Objections to Plaintiff's Trial Exhibits (Weatherly, Grace) (Entered: 07/13/2005)

***DEFICIENT DOCUMENT, to be refiled*** MOTION to Stay by Equal Employment Opportunity Commission. (Attachments: # 1 Exhibit # 2 Exhibit # 3 Exhibit # 4)(Mallon, Keri) Modified on 7/14/2005 (ttm, ). (Entered: 07/14/2005)

***Deficient Document, to be refiled with motion attached*** MOTION to Stay by Equal Employment Opportunity Commission. (Attachments: # 1 Exhibit # 2 Exhibit # 3 # 4 Text of Proposed Order)(Mallon, Keri) Modified on 7/14/2005 (ttm, ). (Entered: 07/14/2005)

MOTION to Stay by Equal Employment Opportunity Commission. (Attachments: # 1 Exhibit # 2 Exhibit # 3 Exhibit # 4 Text of Proposed Order)(Mallon, Keri) (Entered: 07/14/2005)

***FILED IN ERROR. Document # 63, Motion to stay proceedings. PLEASE IGNORE. To be refiled with motion attached*** (ttm, ) (Entered: 07/14/2005)

***FILED IN ERROR. Document # 62, Motion to Stay Proceedings. PLEASE IGNORE. To be refiled with attorney's signature*** (ttm, ) (Entered: 07/14/2005)

ORDER granting in part 64 Motion to Stay. The Court orders the following new deadlines: Proposed Joint Pretrial Order, Motions in limine, Joint Proposed Jury Instructions, Form of Verdict and any Trial Briefs shall be submitted by 12/19/05. Final Pretrial Conference at 9:00 am on 12/22/05. Jury Selection and/or trial at 9:00 am on 1/4/06 to be tried when reached. Signed by Judge Paul N Brown on 7/15/05. cc:attys on 7/15/05 (ttm, ) (Entered: 07/15/2005)

Reset Scheduling Order Deadlines: Final Pretrial Conference set for 12/22/2005 09:00 AM in Ctrm 208 (Sherman) before Judge Paul N Brown. Jury instructions due by 12/19/2005 Jury Selection set for 1/4/2006 09:00 AM in Ctrm 208 (Sherman) before Judge Paul N Brown. Proposed Pretrial Order due by 12/19/2005. (ttm, ) (Entered: 07/15/2005)

MOTION to Continue Jury Trial by Equal Employment Opportunity Commission. (Attachments: # 1 Text of Proposed Order Proposed Order) (Costas, Toby) (Entered: 12/02/2005)

ORDER granting 67 Motion to Continue Jury Trial, the court orders the following new deadlines: Proposed Joint Final Pretrial Order, Motions in limine, Joint Proposed Jury Instructions, Form of Verdict and any Trial Briefs shall be submitted by 5/16/06. Final Pretrial Conference will be held at 9:00 am on 5/19/06, Jury Selection will begin at 9:00 am on 6/5/06, case to be tried when reached . Signed by Judge Paul N Brown on 12/12/05. (ttm, ) (Entered: 12/12/2005)

Reset Scheduling Order Deadlines: Final Pretrial Conference set for 5/19/2006 09:00 AM before Judge Paul N Brown. Jury instructions due by 5/16/2006 Jury Selection set for 6/5/2006 09:00AM before Judge Paul N Brown. Proposed Pretrial Order due by 5/16/2006. (ttm, ) (Entered: 12/12/2005)

ORDER denying 44 Dft Teleservices Marketing Corp's Motion for Summary Judgment . Signed by Judge Paul N Brown on 12/14/05. (ttm, ) (Entered: 12/14/2005)

ORDER for further Briefing on Gen Telemarketing's Motion for summary judgment, additional briefing shall be filed on or before 1/3/06. Signed by Judge Paul N Brown on 12/16/05. (ttm, ) (Entered: 12/16/2005)

TRIAL BRIEF ON INTEGRATED ENTERPRISE THEORY by Equal Employment Opportunity Commission. (Attachments: # 1 Exhibit # 2 Exhibit Exhibit 1a# 3 Exhibit Exhibit 1b# 4 Exhibit Exhibit 2# 5 Exhibit Exhibit 3# 6 Exhibit Exhibit 4# 7 Exhibit Exhibit 5)(Costas, Toby) (Entered: 01/03/2006)

TRIAL BRIEF in Support of Defendant General Telemarketing International, Inc.'s Motion for Summary Judgment by General Telemarketing International, Inc.. (Weatherly, Grace) (Entered: 01/03/2006)

MOTION to Amend/Correct 38 Amended Complaint SECOND AMENDED COMPLAINT by Equal Employment Opportunity Commission. (Attachments: # 1 Exhibit Amended Second Complaint# 2 Text of Proposed Order PROPOSED ORER FILE AMENDED COMPLAINT)(Costas, Toby) (Entered: 01/09/2006)

RESPONSE in Opposition re 73 MOTION to Amend/Correct 38 Amended Complaint SECOND AMENDED COMPLAINT filed by Teleservices Marketing Corporation, General Telemarketing International, Inc.. (Attachments: # 1 Exhibit A)(Weatherly, Grace) (Entered: 01/24/2006)

REPLY to Response to Motion re 73 MOTION to Amend/Correct 38 Amended Complaint SECOND AMENDED COMPLAINT filed by Equal Employment Opportunity Commission. (Costas, Toby) Modified on 2/3/2006 (ttm, ). ***This document REPLACES #75*** (Entered: 01/30/2006)

MEMORANDUM AND OPINION and ORDER DENYING General Telemarketing Intl Inc' motion for summary judgment. Signed by Judge Paul N Brown on 2/8/06. (ttm, )

ORDER, the court anticipates setting time limits for each party to present its case. It is Ordered that by 5/12/06 at 4:00 pm, the parties shall each submit to the court an estimate of the time that party needs to complete the presentation of testimony in this case. The required statements should not be filed with the clerk, but should be submitted only to the court. The court intends to notify the parties of the total time each is alloted by 5/16/06. Signed by Judge Ron Clark on 4/28/06. (ttm, ) (Entered: 05/02/2006)

ORDER denying 73 Motion to file second amended complaint. Signed by Judge Ron Clark on 5/11/06. (ttm, ) (Entered: 05/11/2006)

MOTION to Withdraw as Attorney Keri L. Mallon by Equal Employment Opportunity Commission. (Attachments: # 1 Text of Proposed Order)(Costas, Toby) (Entered: 05/12/2006)

NOTICE of Attorney Appearance by Devika Seth Dubey on behalf of Equal Employment Opportunity Commission (Dubey, Devika) (Entered: 05/12/2006)

MOTION in Limine and Supporting Brief by Teleservices Marketing Corporation, General Telemarketing International, Inc.. (Attachments: # 1 Text of Proposed Order Order on Motion in Limine)(Weatherly, Grace) (Entered: 05/16/2006)

Proposed Jury Instructions by Teleservices Marketing Corporation, General Telemarketing International, Inc.. (Weatherly, Grace) (Entered: 05/16/2006)

Proposed Voir Dire by Equal Employment Opportunity Commission. (Costas, Toby) (Entered: 05/16/2006)

MOTION in Limine by Equal Employment Opportunity Commission. (Attachments: # 1 Text of Proposed Order Order-Motion In Limine) (Costas, Toby) (Entered: 05/16/2006)

Proposed Jury Instructions by Equal Employment Opportunity Commission. (Costas, Toby) (Entered: 05/16/2006)

Proposed Pretrial Order Joint Final Pre-Trial Order by Equal Employment Opportunity Commission. (Attachments: # 1 Exhibit Plaintiff's Exhibit List# 2 Exhibit Defendants' Exhibit List)(Costas, Toby) (Entered: 05/16/2006)

Proposed Jury Instructions by Equal Employment Opportunity Commission. (Costas, Toby) (Entered: 05/16/2006)

***FILED IN ERROR. Atty notified to refile in paper form with original signatures, PLEASE IGNORE.*** NOTICE by Equal Employment Opportunity Commission Notice, Consent & Order of Reference Exercise Jurisdiction by a U.S. Magistrate Judge (Costas, Toby) Modified on 5/17/2006 (dlc, ). (Entered: 05/16/2006)

***FILED IN ERROR. Document # 89, Atty notified to refile in paper form with original signatures. PLEASE IGNORE.*** (dlc, ) (Entered: 05/17/2006)

NOTICE of Hearing: Final Pretrial Conference set for Friday, 5/19/2006 09:00 AM in Video Conferencing Room (Sherman Annex) before Judge Ron Clark. (snh, ) (Entered: 05/17/2006)

ORDER on Limitations of Trial Time, the court now allocates 5.5 hours to Pltf and 5.5 hours to the Dft, in which to present their respective cases . Signed by Judge Ron Clark on 5/17/06. (ttm, ) (Entered: 05/18/2006)

Minute Entry for proceedings held before Judge Ron Clark : Final Pretrial Conference held on 5/19/2006. (Court Reporter Dave Maxwell.) (snh, ) (Entered: 05/19/2006)

ORDER granting 80 Motion to Withdraw as Attorney. Attorney Keri Lyn Mallon terminated . Signed by Judge Ron Clark on 5/19/06. (ttm, ) (Entered: 05/19/2006)

JOINT FINAL PRETRIAL ORDER. Signed by Judge Ron Clark on 5/19/06. (ttm, ) (Entered: 05/25/2006)

RESPONSE to 87 Proposed Pretrial Order, 94 Pretrial Order Defendants' Objections to Plaintiff's Trial Exhibits by Teleservices Marketing Corporation, General Telemarketing International, Inc.. (Weatherly, Grace) (Entered: 05/26/2006)

RESPONSE to 87 Proposed Pretrial Order, 94 Pretrial Order Objections to Plaintiff's Pretrial Deposition Designations by Teleservices Marketing Corporation, General Telemarketing International, Inc.. (Weatherly, Grace) (Entered: 05/30/2006)

***DEFICIENT DOCUMENT, ATTORNEY MUST REFILE*** NOTICE of Attorney Appearance by David C Rivela on behalf of Equal Employment Opportunity Commission (Rivela, David) (Entered: 06/12/2006)

NOTICE of Attorney Appearance by David C Rivela on behalf of Equal Employment Opportunity Commission (Rivela, David) Modified on 6/13/2006 (ttm, ) ***CORRECTED DOCUMENT REPLACES DOCUMENT #98 WHICH WAS DEFICIENT*** (Entered: 06/12/2006)

NOTICE of Hearing: Jury Selection / Trial rescheduled for Monday 7/24/2006 09:00 AM in Ctrm 208 (Sherman) before Judge Ron Clark. (snh, ) (Entered: 06/14/2006)

Proposed Jury Instructions by Equal Employment Opportunity Commission. (Costas, Toby) (Entered: 07/24/2006)

Minute Entry for proceedings held before Judge Ron Clark : Jury Trial day 1 held on 7/24/2006. (Court Reporter Bryn & Associates.) (snh, ) (Entered: 07/26/2006)

Minute Entry for proceedings held before Judge Ron Clark : Voir Dire held on 7/24/2006. (Court Reporter Bryn & Associates.) (snh, ) (Entered: 07/25/2006)

Minute Entry for proceedings held before Judge Ron Clark : Jury Selection held on 7/25/2006. (Court Reporter Bryn & Associates.) (snh, ) (Entered: 07/25/2006)

Jury Impaneled. (snh, ) (Entered: 07/25/2006)