Case: EEOC v. Phoenix Suns Limited Partnership

No Court

No Court

Carly Knight, Frank Dobbin, Alexandra Kalev

COMPLAINT FILED (MAP) (Entered: 06/01/2002)

RETURN OF SERVICE EXECUTED summons/complaint upon dft Phoenix Suns Ltd Prt by service upon Statutory Agent FC Service Corp (Susan Rader) on 5/24/02 (LAD) (Entered: 06/03/2002)

STANDARD CIVIL TRACK INITIAL ORDER by Judge James A. Teilborg that this action...is designated a standard track case; ORDERED that pla shall effect service of the complaint and summons no later than 120 days after the filing of the complaint; FURTHER ORDERED that full compliance with RUle 26(f) is expected prior to the date of the Rule 16 scheduling conference; FURTHER ORDERED taht pla shall serve dft(s) with a copy of this order (cc: all counsel) re: order filed [3-1] (LAD) (Entered: 06/05/2002)

ANSWER to complaint [1-1] by dft Phoenix Suns Ltd Prt (LAD) (Entered: 06/18/2002)

RETURN OF SERVICE EXECUTED summons/complaint upon dft Sports Magic Team by service upon Joe Ginel in Winter Park, Florida on 6/6/02 (LAD) (Entered: 06/19/2002)

ANSWER to pla's complaint [1-1] by dft Sports Magic Team (former emp) (Entered: 07/01/2002)

MOTION for admission pro hac vice as to Dorothy Fleming Green, atty for dft Sports Magic Team [7-1] (former emp) (Entered: 07/01/2002)

NOTICE by dft Phoenix Suns Ltd Prt of service of answer (LAD) (Entered: 07/02/2002)

ORDER by Judge James A. Teilborg granting motion for admission pro hac vice as to Dorothy Fleming Green, atty for dft Sports Magic Team [7-1] (cc: all counsel) (LAD) (Entered: 07/02/2002)

ORDER by Judge James A. Teilborg scheduling conf set for 4:00 8/13/02 ; FURTHER ORDERED that all parties are directed to meet at least 21 days before the preliminary pretrial conference; FURTHER ORDERED that counsel shall jointly file their proposed case management plan with the Clerk of Court not less than 5 business days before the preliminary pretrial conference; FURTHER ORDERED that the Clerk of Court send copies of this order to all counsel of record and to all parties, if any, appearing in propria persona (cc: all counsel) (LAD) (Entered: 07/16/2002)

CASE MGT PLAN/REPORT: joint pretrial order ddl 8/15/03; discovery cutoff 4/25/03; dispositive motions filing ddl is 6/27/03 (LAD) (Entered: 08/09/2002)

SCHEDULING ORDER by Judge James A. Teilborg ; discovery due 4/25/03 ; dispositive motions due 6/27/03 (cc: all counsel) re: order (scheduling) [13-1] (LAD) (Entered: 08/14/2002)

NOTICE of compliance of initial disclosure statement pursuant to FRCivP 26(a) by dft Phoenix Suns Ltd Prt (LAD) (Entered: 08/28/2002)

NOTICE of compliance of initial disclosure statement pursuant to FRCivP 26(a) by pla EEOC (LAD) (Entered: 08/28/2002)

NOTICE of compliance of initial disclosure statement pursuant to FRCivP 26(a) by dft Sports Magic Team (LAD) (Entered: 08/28/2002)

NOTICE of service of discovery by pla EEOC . (LAD) (Entered: 09/26/2002)

NOTICE of service of discovery by dft Phoenix Suns Ltd Prt . (LAD) (Entered: 10/04/2002)

NOTICE of service of discovery by dft Phoenix Suns Ltd Prt (MAP) (Entered: 11/12/2002)

NOTICE by pla EEOC of Service of Discovery Responses (TCA) (Entered: 11/12/2002)

NOTICE of service of discovery by pla EEOC . (former emp) (Entered: 11/12/2002)

MOTION to extend time to file an amendment to the complaint (to 11/18/02) by pla EEOC [22-1] (proposed amended complaint not provided) (1st request) (LAD) (Entered: 11/12/2002)

NOTICE of service of verification of answers to pla's first set of non-uniform interrogatories (discovery) by dft Sports Magic Team on 11/7/02. (former emp) Modified on 11/14/2002 (Entered: 11/14/2002)

NOTICE of service of responses to pla's 1st set of non-uniform interrogatories and 1st request for production of documents (discovery) by dft Sports Magic Team on 10/28/02. (former emp) (Entered: 11/14/2002)

ORDER by Judge James A. Teilborg granting motion to extend time to file an amendment to the complaint (to 11/18/02) by pla EEOC [22-1] (proposed amended complaint not provided); ORDERED granting the motion and extending the time for filing an amendment of the complaint to 11/18/02 (cc: all counsel) (LAD) (Entered: 11/14/2002)

MOTION to extend time to file an amendment to the complaint (to 30 days from the date the Commission receives any supplemental applicant information sought during discovery or confirmation that dfts do not possess the information sought) by pla EEOC [26-1] (proposed amended complaint not provided) (2nd request) (LAD) (Entered: 11/20/2002)

NOTICE of compliance of 1st supplemental disclosure statement pursuant to FRCivP 26(a) by pla EEOC (LAD) (Entered: 11/20/2002)

NOTICE of service of discovery by pla EEOC (LAD) (Entered: 12/10/2002)

RESPONSE by dft Phoenix Suns Ltd Prt to motion to extend time to file an amendment to the complaint (to 30 days from the date the Commission receives any supplemental applicant information sought during discovery or confirmation that dfts do not possess the information sought) by pla EEOC [26-1] (proposed amended complaint not provided) (LAD) (Entered: 12/10/2002)

RESPONSE (MEMO IN OPPOSITION) by dft Sports Magic Team to motion to extend time to file an amendment to the complaint (to 30 days from the date the Commission receives any supplemental applicant information sought during discovery or confirmation that dfts do not possess the information sought) by pla EEOC [26-1] (proposed amended complaint not provided) (LAD) (Entered: 12/10/2002)

NOTICE of service of supplemental responses to pla's first set of non-uniform interrogatories and first request for production of documents (discovery) on 12/4/02 by dft Sports Magic Team . (former emp) (Entered: 12/12/2002)

AFFIDAVIT of Dorothy F. Green in support of supplemental responses to pla's first set of non-uniform interrogatories and first request for production of documents [31-1] by dft Sports Magic Team (former emp) (Entered: 12/12/2002)

NOTICE OF FILING TO THIS COURT by dft Sports Magic Team of executed original affidavit of Dorothy F. Green in support of dft Sports Magic Team, Inc.'s memorandum in opposition to pla's second request for extenstion of time to file an amendment to the complaint on 12/9/02 (former emp) (Entered: 12/12/2002)

REPLY by pla EEOC to responses to motion to extend time to file an amendment to the complaint (to 30 days from the date the Commission receives any supplemental applicant information sought during discovery or confirmation that dfts do not possess the information sought) by pla EEOC [26-1] (proposed amended complaint not provided) (LAD) (Entered: 12/23/2002)

NOTICE of service of discovery by dft Sports Magic Team (LAD) (Entered: 01/03/2003)

NOTICE of compliance of 2nd supplemental disclosure statement pursuant to FRCivP 26(a) by pla EEOC (LAD) (Entered: 01/09/2003)

NOTICE of service of discovery by dft Sports Magic Team . (LAD) (Entered: 01/24/2003)

NOTICE of service of discovery by dft Phoenix Suns Ltd Prt serving; Responses to pla's First Request for Admissions, Second set of Non-Uniform Interrogatories, and Second Request for Production of documents. (KMG) (Entered: 01/28/2003)

NOTICE by pla EEOC OF TAKING VIDEO DEPO OF Felisa Israel on the following date(s): 2/14/03 at noon (LAD) (Entered: 02/05/2003)

NOTICE of service of discovery by pla EEOC (LAD) (Entered: 02/12/2003)

ORDER by Judge James A. Teilborg granting stipulation to extend time deadlines for expert identification, discovery (to 6/27/03) and dispositive motions (to 8/29/03) by pla EEOC, dft Phoenix Suns Ltd Prt, dft Sports Magic Team; EEOC deadline to identify expert witnesses and submit expert reports: 4/11/03; dfts' deadline to identify expert witnesses and submit expert reports: 5/9/03; parties' deadline to identify expert rebuttal witnesses and submit expert rebuttal reports: 5/30/03; discovery ddl reset for 6/27/03; dispositive motions ddl reset to 8/29/03 (cc: all counsel) (LAD) (Entered: 02/12/2003)

NOTICE by dft Phoenix Suns Ltd Prt OF TAKING DEPO OF Kathryn Tomlinson on the following date(s): 3/11/03 at 10:30 am (LAD) (Entered: 02/18/2003)

NOTICE by pla EEOC OF TAKING VIDEO DEPO OF Jodi Hellman on the following date(s): 3/4/03 at 11 am (LAD) (Entered: 02/24/2003)

NOTICE by pla EEOC OF TAKING VIDEO DEPO OF Timothy Glancey on the following date(s): 3/13/03 at 10 am (LAD) (Entered: 02/24/2003)

NOTICE by dft Sports Magic Team OF TAKING DEPO DUCES TECUM OF Kathryn Tomlinson on the following date(s): 3/11/03 at 10:30 am (LAD) (Entered: 02/25/2003)

NOTICE by pla EEOC OF TAKING RULE 30(b)(6) DEPO OF Phoenix Suns Limited Partnershp on the following date(s): 3/6/03 at 1 pm (LAD) (Entered: 02/27/2003)

NOTICE of service of discovery by dft Sports Magic Team (LAD) (Entered: 03/06/2003)

NOTICE of compliance of 3rd supplemental disclosure statement pursuant to FRCivP 26(a) by pla EEOC (LAD) (Entered: 03/12/2003)

NOTICE by dft Phoenix Suns Ltd Prt OF CONTINUATION OF DEPO OF Kathyrn Tomlinson on the following date(s): 4/2/03 at 9:30 am (LAD) (Entered: 03/19/2003)

NOTICE by dft Sports Magic Team OF CONTINUATION OF DEPO OF Kathryn Tomlinson on the following date(s): 4/2/03 at 9:30 am (LAD) (Entered: 03/28/2003)

MINUTE ORDER Pending before this Court is Plaintiff's Motion to Extend Time to File Amended Complaint (doc. #26). Because the amount of time requested has now elapsed, IT IS ORDERED that Plaintiff shall lodge a proposed amended complaint within ten days of the date of this order. (cc: all counsel) [52-1] (TLB) (Entered: 04/29/2003)

1ST AMENDED NOTICE by pla EEOC OF TAKING RULE 30(b)(6) DEPO OF Phoenix Suns Limited Partnership on the following date(s): 5/6/03 at 10 am (LAD) (Entered: 05/02/2003)

Stipulated MOTION to Extend Deadlines for Identification of Expert Witnesss and Completion of All Discovery by pla, dfts [54-1] (SAT) (Entered: 05/12/2003)

LODGED Amended Complaint by pla (SAT) (Entered: 05/14/2003)

ORDER by Judge James A. Teilborg granting Stipulated Motion to Extend Deadlines for Identification of Expert Witnesss and Completion of All Discovery by pla, dfts [54-1]; FURHTER ORDERED that (1) Defendants' deadline to identify expert witnesses and submit expert reports will be 6/6/03; (2) the parties' deadline to identify expert rebuttal witnesses and submit expert reports will be 6/27/03; and (3) the parties' deadline to complete al discovery, including that related to expert witnesses, will be 8/8/03; FURTHER ORDERED that the deadline for filing dispositive motions (8/29/03) is not extended (cc: all counsel) (SAT) (Entered: 05/14/2003)

MINUTE ENTRY before Judge James A. Teilborg . Crt Rptr: Vicki Reger. Telephonic appearances: David P. Lopez for pla EEOC, Kandace B. Majoros for dft Phx Suns, and Dorothy F. Green for dft Sport Magic Team. Telephonic discovery dispute held. (1) The Court will allow a presumptive 4 additional hours for deposition of Katherine Tomlinson. (2) Regarding unredacted/redacted journals and calendars, the Court fids that the defendant has received what they requested. The Court will not require production of unredacted versions of journals and calendars and will not intervene in terms of status of the request. [cc: JAT] [56-3] (TLB) (Entered: 05/15/2003)

MINUTE ORDER Pending before this Court is Plaintiff's Motion to Extend Time (to January 4, 2003) to file an amended complaint. On May 13, 2003, Plaintiff lodged the proposed amended complaint. IT IS ORDERED that by May 23, 2003, each Defendant shall file a memorandum advising the Court of whether each Defendant objects to the lodged amended complaint being filed. IT IS FURTHER ORDERED that if either Defendant objects to the lodged amended complaint being filed, such Defendant shall include the basis for such objection in the May 23, 2003 filing. IT IS FURTHER ORDERED that if either Defendant objects to the lodged amended complaint being filed, Plaintiff shall file a response to such objection by June 2, 2003. (cc: all counsel) [57-1] (TLB) (Entered: 05/16/2003)

MOTION for clarification of discovery order (minute) [57-1] (re deposition of Kathryn Tomlinson) by pla EEOC [58-1] ***STRICKEN per order [59-1] dated 5/20/03*** (LAD) Modified on 05/23/2003 (Entered: 05/19/2003)

NOTICE by pla OF TAKING DEPO OF Cheryl Naumann on the following date(s): 6/10/03 (SAT) (Entered: 05/20/2003)

NOTICE by pla OF TAKING DEPO OF Harvey Shank on the following date(s): 6/12/03 (SAT) (Entered: 05/20/2003)

MINUTE ORDER IT IS ORDERED that Plaintiff's Motion for Clarification of Discovery Order [58-1] (filed on May 16, 2003) is hereby stricken for having been filed in violation of this Court's August 14, 2002 Scheduling Order (specifically page 4, lines 4-13) and the Clerk of the Court shall write "stricken" across the first page of the Motion. (cc: docket clerk, all counsel) [59-1] (TLB) (Entered: 05/20/2003)

RESPONSE by dft Phoenix Suns Ltd Prt to motion for clarification of discovery order (minute) [57-1] (re deposition of Kathryn Tomlinson) by pla EEOC [58-1] ***STRICKEN per order [59-1] dated 5/20/03*** [58-1] (LAD) (Entered: 05/23/2003)

RESPONSE (MEMO IN OPPOSITION) by dft Sports Magic Team to motion to extend time to file an amendment to the complaint (to 30 days from the date the Commission receives any supplemental applicant information sought during discovery or confirmation that dfts do not possess the information sought) by pla EEOC [26-1] (proposed amended complaint not provided) (LAD) (Entered: 05/29/2003)

RESPONSE (OBJECTIONS) by dft Phoenix Suns Ltd Prt to motion to extend time to file an amendment to the complaint (to 30 days from the date the Commission receives any supplemental applicant information sought during discovery or confirmation that dfts do not possess the information sought) by pla EEOC [26-1] (proposed amended complaint not provided) (LAD) (Entered: 05/29/2003)

NOTICE by dft Phoenix Suns Ltd Prt OF CONTINUATION OF DEPO OF Kathryn Tomlinson on the following date(s): 6/12/03 at 10 am (LAD) (Entered: 05/29/2003)

REPLY by pla EEOC to response (objections of dft Phoenix Suns) to motion to extend time to file an amendment to the complaint (to 30 days from the the Commission receives any supplemental applicant information sought during discovery or confirmation that dfts do not possess the information sought) by pla EEOC [26-1] (proposed amended complaint not provided) (LAD) (Entered: 06/04/2003)

REPLY by pla EEOC to response (memo in opposition of dft Sports Magic) to motion to extend time to file an amendment to the complaint (to 30 days from the the Commission receives any supplemental applicant information sought during discovery or confirmation that dfts do not possess the information sought) by pla EEOC [26-1] (proposed amended complaint not provided) (LAD) (Entered: 06/04/2003)

STIPULATED MOTION to extend deadlines for identification of expert witnesses by pla EEOC, dft Phoenix Suns Ltd Prt, dft Sports Magic Team [68-1] (2nd request) (LAD) (Entered: 06/04/2003)

2ND NOTICE by dft Sports Magic Team OF CONTINUATION TAKING DEPO DUCES TECUM OF Kathryn Tomlinson on the following date(s): 6/12/03 at 10 am (LAD) (Entered: 06/04/2003)

ORDER by Judge James A. Teilborg granting motion to extend deadlines for identification of expert witnesses by pla EEOC, dft Phoenix Suns Ltd Prt, dft Sports Magic Team [68-1]; ORDERED that dfts' deadline to identify expert witnesses and submit expert reports will be 6/27/03; the parties deadline to identify expert rebuttal witnesses and submit expert reports will be 7/18/03 (cc: all counsel) (LAD) (Entered: 06/04/2003)

NOTICE of service of discovery by pla EEOC (LAD) (Entered: 06/13/2003)

ORDER by Judge James A. Teilborg denying as moot the motion to extend time to file an amendment to the complaint (to 30 days from the date the Commission receives any supplemental applicant information sought during discovery or confirmation that dfts do not possess the information sought) by pla EEOC [26-1] (proposed amended complaint not provided); lodged document [0-0] terminated; ORDERED that pla's motion to amend the complaint is granted; FURTHER ORDERED that Clerk of Court shall file pla's lodged amended complaint (lodged on 5/13/03) (cc: all counsel) (LAD) (Entered: 06/13/2003)

AMENDED COMPLAINT by pla EEOC; jury demand [1-1] (OK to file per order #73 6/13/03) (LAD) (Entered: 06/13/2003)

1ST AMENDED NOTICE by pla EEOC OF TAKING DEPO OF Harvey Shank on the following date(s): 6/24/03 at 9 am (LAD) (Entered: 06/18/2003)

NOTICE of compliance of 4th supplemental disclosure statement pursuant to FRCivP 26(a) by pla EEOC (LAD) (Entered: 06/24/2003)

NOTICE of service of discovery by dft Phoenix Suns Ltd Prt (LAD) (Entered: 06/27/2003)

ANSWER to complaint (amended) [74-1] by dft Phoenix Suns Ltd Prt (LAD) (Entered: 06/27/2003)

ANSWER to complaint (amended) [74-1] by dft Sports Magic Team (LAD) (Entered: 07/02/2003)

NOTICE of service of discovery by dft Sports Magic Team - first request for admissions to pla, second set of interrogatories to pla and second request for production of documents to pla. (CMM) (Entered: 07/14/2003)

NOTICE of service of discovery by dft Sports Magic Team (LAD) (Entered: 07/15/2003)

NOTICE by pla EEOC OF TAKING DEPO OF Maggie Garcia on the following date(s): 7/24/03 (FMP) (Entered: 07/17/2003)

NOTICE by pla EEOC OF TAKING DEPO OF Robert Wolfe on the following date(s): 08/01/03 (FMP) (Entered: 07/17/2003)

NOTICE by pla EEOC OF TAKING DEPO OF Kip Helt on the following date(s): 8/07/03 (FMP) (Entered: 07/17/2003)

NOTICE of compliance of 5th Supplemental disclosure statement pursuant to FRCivP 26(a) by pla EEOC (FMP) (Entered: 07/17/2003)

NOTICE by pla EEOC OF TAKING DEPO OF Maggie Garcia on the following date(s): 7/23/03 at 9:30 am (LAD) (Entered: 07/18/2003)

1ST AMENDED NOTICE by pla EEOC OF TAKING DEPO OF Robert Wolfe on the following date(s): 8/1/03 at 1:30 pm (LAD) (Entered: 07/18/2003)

STIPULATED MOTION to extend discovery and dispositive motion deadlines by pla, dfts [89-1] (2nd request) (LAD) (Entered: 07/23/2003)

NOTICE of service of discovery by dft Phoenix Suns Ltd Prt . (SAT) (Entered: 07/23/2003)

ORDER by Judge James A. Teilborg granting motion to extend discovery and dispositive motion deadlines by pla, dfts [89-1] discovery ddl reset for 9/12/03; dispositive motions ddl reset to 10/12/03 (cc: all counsel) (LAD) (Entered: 07/23/2003)

REVISED STIPULATED MOTION to extend discovery and dispositive motion deadlines by pla EEOC, dft Phoenix Suns Ltd Prt, dft Sports Magic Team [92-1] (LAD) (Entered: 08/01/2003)

ORDER by Judge James A. Teilborg granting motion to extend discovery and dispositive motion deadlines by pla EEOC, dft Phoenix Suns Ltd Prt, dft Sports Magic Team [92-1] discovery ddl reset for 9/12/03; dispositive motions ddl reset to 10/17/03 (cc: all counsel) (LAD) (Entered: 08/04/2003)

NOTICE of service of discovery by pla. (SAT) (Entered: 08/07/2003)

NOTICE of compliance of 6th supplemental disclosure statement pursuant to FRCivP 26(a) by pla EEOC (LAD) (Entered: 08/08/2003)

NOTICE of service of discovery by pla EEOC (LAD) (Entered: 08/15/2003)

NOTICE of compliance of 1st supplemental disclosure statement pursuant to FRCivP 26(a) by dft Phoenix Suns Ltd Prt (LAD) (Entered: 08/18/2003)

NOTICE OF SETTLEMENT filed by pla EEOC, dft Phoenix Suns Ltd Prt (dft Sports Magic Team Inc remains) (LAD) (Entered: 09/10/2003)

NOTICE OF SETTLEMENT filed by pla EEOC, dft Sports Magic Team; possible dism ddl set for 11/10/03 (this was the sole remaining dft) (LAD) (Entered: 09/11/2003)

ORDER by Judge James A. Teilborg re: settlement notice [98-1]; stay deadline set for 10/11/03; Possible dismissal set for 10/10/03 ; case stayed as to all proceedings ; ORDERED that this action is stayed for 30 days so parties may submit a final consent decree; the parties shall file the consent decree with the Court no later than 10/8/03; FURTHER ORDERED that on 10/10/03, the Clerk of Court shall automatically dismiss tis acase, without further notice, unless either the consent decree has been filed or a party has moved for reinstatement to the Court's trial calendar (cc: all counsel) (LAD) (Entered: 09/11/2003)

MOTION (Joint) for Entry of Consent Decree by pla EEOC, dft Phoenix Suns Ltd Prt [101-1] (SAT) (Entered: 10/08/2003)

MOTION (Joint) for Entry of Consent Decree by pla EEOC, dft Sports Magic Team [102-1] (SAT) (Entered: 10/08/2003)

CONSENT JUDGMENT by Judge James A. Teilborg : granting motion (Joint) for Entry of Consent Decree by pla EEOC, dft Phoenix Suns Ltd Prt [101-1] dismissing dft Phoenix Suns Ltd Prt ; ORDERE ADJDUGED AND DECREED ... this consent decree resolves all claims by the Commission, including all claims asserted by the Commission on behalf of Kathryn Tomlinson and class members Makia White and Nathasha Jenkins, against the Phoenix Suns in this lawsuit, including without limitation, claims for back pay, compensatory and punitive damages, injunctive relief, costs and attorneys' fees; this consent decree conforms with the Federal Rules of Civil Procedure and Title VII....; this decree applies to the Phoenix Suns, its officers, agents, employees, successors ans assigns; the decree also requires that Phoenix Suns take reasonable steps to ensure that any 3rd party involved in the recruitment, hiring and advertising of the Zoo Crew or any similar successor entertainment team who provides services pursuant to the decree complies with the decree with respect to any services provided; for the purposes of this decree, "Game Entertainment" means all on-court, non-sports entertainment provided by the Phoenix Suns during Phoenix Suns home games, including the Zoo Crew and Phoenix Suns Dancers, but excluding occasional performers (such as anthem singers and halftime acts) and television and radio broadcast talent; INJUNCTIVE RELIEF for the duration of the decree, the Phoenix Suns will not (a) discriminate against any employee based on sex, or (b) retaliate against any employee because he or she (i) opposed discriminatory practices made unlawful by Title VII, (ii) filed a charge or is assisting or participating in the filing of a charge of discrimination, or (iii) assisted or participated in an investigation or proceeding under Title VII; for the duration of the decree, the Suns agree to conduct recruitment, hiring and advertisement practices for Game Entertainment positions in a non-discriminatory manner and to state the same in all recruitment and advertisement materials; for the duration of the decree, the Suns shall affirmatively recruit women for the Zoo Crew or successor entertainment team; MONETARY RELIEF the Phoenix Suns will pay $82,500 to Ms Tomlinson and the other class members in 2 payments; this payment represents payment of compensatory damages; CORRECTIVE POLICIES AND PRACTICES the Phoenix Suns will post, for the duration of the decree, in a prominent place frequented by its employees at all its facilities, the notice attached as exhibit B; within 3 mos...and on an annual basis, the Suns will provide Title VII training for all employees with supervisory responsibilites for hiring, recruiting or preparing recruitment advertisement; RECORD KEEPING AND REPORTING that Phoenix Suns shall maintain all records concerning its implementation of this consent decree for the entire term of this consent decree; each party shall bear its own costs in conjunction with the maintenance of records, preparation of any report, access or copy of records or interview of employees required by the consent decree; MISCELLANEOUS PROVISIONS within 30 days of the entry of this decree, the Phoenix Suns' Director of Human Resources shall enter a letter of apology to Kathryn Tomlinson; within 30 days of the entry of this decree, the Phoenix Suns agree to provide a reference letter attached as exhibit C to Kathryn Tomlinson; the Court shall retain jurisdiction of this action for a period of 3 yrs after entry of the consent decree (cc: all counsel/jgm drawer) (LAD) (Entered: 10/16/2003)