Case: EEOC v. UNICOM ELECTRIC, INC.

EEOC v. Unicom Electric Inc, et al

EEOC v. Unicom Electric, Inc.

EEOC v. Unicom Electric, Inc.

No Court

EEOC v. Unicom Electric, Inc.

EEOC v. Unicom Electric, Inc.

Carly Knight, Frank Dobbin, Alexandra Kalev

COMPLAINT filed Summons(es) issued referred to Discovery Jennifer T. Lum (jag) (Entered: 09/10/2002)

CERTIFICATION OF INTERESTED PARTIES filed by plaintiff EEOC (jag) (Entered: 09/10/2002)

NOTICE TO COUNSEL ORDER re strict compliance w/the provisons of Local Rules & Fed Rules of Civil Procedures (See doc for fur details) by Judge Christina A. Snyder (ir) (Entered: 09/16/2002)

ANSWER filed by defendant Unicom Electric Inc to complaint [1−1]; jury demand (pj) (Entered: 10/01/2002)

CERTIFICATION OF INTERESTED PARTIES filed by defendant Unicom Electric Inc (pj) (Entered: 10/01/2002)

MINUTES: This matter is set for a scheduling conference at 11:00 1/13/03 ; Parties are reminded of their obligations to disclose information & confer on a discovery plan not later than 21 days priro to the date of the Rule 16(b) scheduling conference & to report to the Court not later than 14 days after they confer on a discovery plan; Failure to comply may lead to the imposition of sanctions (See document for further details) IT IS SO ORDERED by Judge Christina A. Snyder CR: None present (ir) (Entered: 10/28/2002)

JOINT REPORT AND PROPOSED JOINT DISCOVERY PLAN filed; est length of trial 10 − 14 days for plaintiff, and four (4) to six (6) days for defendants (jp) (Entered: 11/20/2002)

PROOF OF SERVICE by plaintiff EEOC on 11/22/02 of Subpoena in a Civil Case by seving Adriana Preciado (ir) (Entered: 12/04/2002)

PROOF OF SERVICE by defendant Unicom Electric Inc on 11/26/02 of Subpoena in a civil case; Party served: Marie Younger (nhac) (Entered: 12/11/2002)

PROOF OF SERVICE by defendant Unicom Electric Inc on 12/5/02 of Subpoena in a Civil Case (See document for further details) (ir) (Entered: 01/02/2003)

PROOF OF SERVICE by defendant Unicom Electric Inc on 12/20/02 of Civil Subpoena (ir) (Entered: 01/03/2003)

PROOF OF SERVICE by defendant Unicom Electric Inc on 12/20/02 of Civil Subpoena on Los Angeles Brotherhood Crusade by serving Peggie Oliver, Custodian of Records (ir) (Entered: 01/03/2003)

PROOF OF SERVICE by defendant Unicom Electric Inc on 12/20/02 of Civil Subpoena (ir) (Entered: 01/06/2003)

MINUTES: Scheduling conference held & set the following dates: Last day to add parties or amend pleadings: 2/28/03 (Last day to file motion to add); Discovery cut−off set on 11/1/03 (Discovery should be completed or motion(s) heard); Pretrial Conference set for 11:00 1/26/04; 10−14 day estimate jury trial set on 9:30 2/17/04 ; motion filing cut−off 11/3/03 (Last day to file motion) IT IS SO ORDERED by Judge Christina A. Snyder CR: Laura Elias (ir) (Entered: 01/16/2003)

NOTICE OF MOTION by plaintiff EEOC to quash Pre−employment records subpoenas as to defendant Unicom Electric Inc dba Unicom Global Systems Solution & Unity in Communications ; motion hearing set for 10:00 2/18/03 (ir) (Entered: 01/23/2003)

JOINT STIPULATION filed on motion to quash Pre−employment records subpoenas as to defendant Unicom Electric Inc dba Unicom Global Systems Solution & Unity in Communications [15−1] (ir) (Entered: 01/23/2003)

NOTICE OF MOTION by plaintiff EEOC to quash Post−Employment Records subpoenas as to defendant Unicom Electric Inc dba Unicom Global Systems Solution & Unity in Communications ; motion hearing set for 10:00 2/18/03 (ir) (Entered:

DECLARATION of Elizabeth Esparza−Cervantes by plaintiff EEOC in support of Plf's motion to quash Post−Employment Records subpoenas as to defendant Unicom Electric Inc dba Unicom Global Systems Solution & Unity in Communications [16−1] (ir) (Entered: 01/23/2003)

DECLARATION of Elizabeth Esparza−Cervantes by plaintiff EEOC in support of Plf's motion to quash Pre−employment records subpoenas to defendant Unicom Electric Inc dba Unicom Global Systems Solution & Unity in Communications [15−1] (ir) (Entered: 01/23/2003)

DECLARATION of Brian Woodard by plaintiff EEOC in support of it's motion to quash Post−Employment Records subpoenas as to defendant Unicom Electric Inc dba Unicom Global Systems Solution & Unity in Communications [16−1] (ir) (Entered: 01/23/2003)

DECLARATION of Brian Woodard by plaintiff EEOC in support of its' motion to quash Pre−employment records subpoenas as to defendant Unicom Electric Inc dba Unicom Global Systems Solution & Unity in Communications [15−1] (ir) (Entered: 01/23/2003)

DECLARATION of Stuart L Leviton by defendant Unicom Electric Inc in support of it's opposition to Plf's motions to quash [15−1], [16−1] (ir) (Entered: 01/23/2003)

NOTICE AND REQUEST Of Settlement Procedure Selection fld Parties request to apr bef a randomly selected judicial officer frm the Civil Settlement Panel for sttlmnt procdgs Order by Judge Christina A. Snyder denying settlement procedure selection request [22−1] (rn) (Entered: 02/03/2003)

NOTICE OF MOTION AND MOTION by plaintiff EEOC to quash deposition subpoena as to Commission employee Cecilia Sanchez , or in the alternative for protective order for deposition subpoena of Investigator Cecilia Sanchez ; motion hearing set for 10:00 3/4/03; Lodged Proposed Order (ir) (Entered: 02/07/2003)

DECLARATION of EEOC Chair Cari M Dominguez by plaintiff EEOC in support of Plf's motion to quash deposition subpoena as to Commission employee Cecilia Sanchez [23−1], or in the alternative a protective order for deposition subpoena of Investigator Cecilia Sanchez [23−2] (ir) (Entered: 02/07/2003)

DECLARATION of Cecilia Sanchez by plaintiff EEOC re Plf's motion to quash deposition subpoena as to Commission employee Cecilia Sanchez [23−1], or in the alternative for protective order for deposition subpoena of Investigator Cecilia Sanchez [23−2] (ir) (Entered: 02/07/2003)

DECLARATION of Elizabeth Esparza−Cervantes by plaintiff EEOC re Plf's motion to quash deposition subpoena as to Commission employee Cecilia Sanchez [23−1], or in the alternative a protective order for deposition subpoena of Investigator Cecilia Sanchez [23−2] (ir) (Entered: 02/07/2003)

JOINT STIPULATION filed re motion to quash deposition subpoena as to Commission employee Cecilia Sanchez [23−1], or in the alternative for protective order for deposition subpoena of Investigator Cecilia Sanchez [23−2] (ir) (Entered: 02/07/2003)

PROOF OF SERVICE by plaintiff EEOC on 2/6/03 of Plf's Notice of motion & motion to quash or in the alternative a protective order for deposition subpoena of Investigator Cecilia Sanchez (See document for further details) (ir) (Entered: 02/07/2003)

DECLARATION of Stuart L Leviton by defendant Unicom Electric Inc in support of its' opposition to Plf's motion to quash deposition subpoena as to Commission employee Cecilia Sanchez [23−1], [23−2] (ir) (Entered: 02/07/2003)

SUPPLEMENTAL MEMORANDUM OF LAW IN SUPPORT by plaintiff EEOC of motion to quash Pre−employment records subpoenas as to defendant Unicom Electric Inc dba Unicom Global Systems Solution & Unity in Communications [15−1] (shb) (Entered: 02/12/2003)

MINUTES: (IN CHAMBERS) Court has reviewed Plf's motion to quash Pre−employment & Post−Employment Records [15−1] [16−1] filed 1/22/03 & has determined that this matter is appropriate for decision without oral argument; Therefore hearing scheduled for 2/18/03 is hereby taken off calendar; Parties will be advised of this Court's ruling by Discovery Jennifer T. Lum (ir) (Entered: 02/14/2003)

MINUTES: (IN CHAMBERS) re (1) Plf's motion to quash Pre−employment records subpoenas [15−1], & (2) Plf's motion to quash Post−Employment Records subpoenas [16−1]; Plf's motion to quash subpoena for pre−employment records as to the subpoenas issued to Creative Computers Inc, and Capital Records Inc is GRANTED in part & DENIED in part; Parties are ORDERED to jointly prepare a Stipulated Protective Order for the purposes of addressing any privacy issues arising from the production of such documents; (2) Plfs' motion to quash post−employment records subpoenas as to the subpoean issued to Los Angeles Brotherhood Crusade & African American Unity Center is GRANTED in part & DENIED in part; Parties are ordered to prepare a Stipulated Protective Order for the purpose of addressing any privacy issues arising from the production of such documents (See document for further details) by Discovery Jennifer T. Lum CR: N/A (ir) (Entered: 02/19/2003)

PLACED IN FILE − NOT USED; [Proposed] Order re Plf's Notice of motion & motion to Quash Post−Employment Records Subpoenas; lodged 1/22/03 by Plf (ir) (Entered: 02/19/2003)

PLACED IN FILE − NOT USED; [Proposed] Order re Plf's Notice of motion & motion to Quash Pre−Employment Records Subpoenas; lodged 1/22/03 by Plf (ir) (Entered: 02/19/2003)

SETTLEMENT PROCEDURE SELECTION: 2nd Notice, Request and ORDER by Judge Christina A. Snyder referring Settlement Conference to Discovery Margaret A. Nagle , settlement conference 11/13/03 (ir) (Entered: 02/20/2003)

MINUTES: (IN CHAMBERS) Court has reviewed the Plf's motion to quash deposition subpoena as to Commission employee Cecilia Sanchez [23−1], [23−2] & has determined that this matter is approprirate for decision without oral argument; Therefore the hearing scheduled for 3/4/03 is hereby taken off calendar; Parties will be advised of this Court's ruling by Discovery Jennifer T. Lum (ir) (Entered: 02/24/2003)

SUPPLEMENTAL MEMORANDUM OF LAW by plaintiff EEOC in support of plaintiff's motion to quash [23−1] or, in the alternative, a protective order for deposition subpoena of Investigator Cecilia Sanchez [23−2] (jp) (Entered: 02/27/2003)

MINUTES: (IN CHAMBERS) Pursuant to the Stipulation & Order signed by District Judge Christina A Snyder referring settlement purposes to Discovery Margaret A. Nagle ; Settlement conference 10:00 11/13/03 at 312 N Spring St LA, CA in Courtroom "B" 8th Floor; On or before 11/6/03 each party shall deliver or fax to the chambers of Magistrate Judge Margaret A Nagle at 213−894−8541 a Confidential Settlement Conference Statement; Statement which may be in the form of a letter shall contain the following information; Each party shall appear at the settlement conference in person absent Court permission to participate telephonically (See document for further details) by Discovery Margaret A. Nagle CR: N/A (ir) (Entered: 03/05/2003)

STIPULATION and ORDER by Judge Christina A. Snyder without addresssing the validity of any of Unicom's alleged defenses Unicom may file its 1st amended answer (ir) (Entered: 03/05/2003)

FIRST AMENDED ANSWER [4−1] by defendant Unicom Electric Inc (ir) (Entered: 03/05/2003)

PLACED IN FILE − NOT USED: [Proposed] Order Re: Plaintiff's Notice of Motion and Motion to Quash or in the Alternative a Protective Order for Deposition Subpoena of Investigator Cecilia Sanchez; lodged 02/06/03 (ln) (Entered: 03/20/2003)

NOTICE OF CHANGE Of Firm Name filed by attorneys Stuart L Leviton , Robert A Levinson for defendant Unicom Electric Inc (Effective 7/1/03 Levinson & Kaplan APC has changed its name to Levinson Kaplan Arshonsky & Kurtz APC) (ir) (Entered: 06/25/2003)

NOTICE OF MOTION AND MOTION by plaintiff EEOC to compel Defendant's responses to EEOC's Discovery Requests ; motion hearing set for 10:00 10/21/03; Lodged Proposed Order (ir) (Entered: 10/02/2003)

JOINT STIPULATION filed re Plaintiff's motion to compel Defendant's responses to EEOC's Discovery Requests [42−1] (ir) (Entered: 10/02/2003)

DECLARATION of Elizabeth Esparza−Cervantes by plaintiff EEOC in support of its' motion to compel Defendant's responses to EEOC's Discovery Requests [42−1] (ir) (Entered: 10/02/2003)

RECEIPT OF TRANSCRIPT of proceedings for the following date(s): 1/13/03 (Re:) CR: Laura Elias (weap) (Entered: 10/02/2003)

TRANSCRIPT filed for proceedings held on 1/13/03 (weap) (Entered: 10/02/2003)

DECLARATION of Elizabeth Esparza−Cervantes by plaintiff EEOC in support of class member disclosure list (rrey) (Entered: 10/10/2003)

PLAINTIFFS CLASS MEMBER DISCLOSURE LIST (rrey) (Entered: 10/10/2003)

NOTICE OF MOTION AND MOTION by defendant Unicom Electric Inc for order to preclude plaintiff EEOC from obtaining individual specific relief on behalf of any individual following the EEOC's failure to comply with the court's order re class member designation ; Memorandum of points and authorities in support thereof ; motion hearing set for 10:00 11/10/03 (shb) (Entered: 10/22/2003)

DECLARATION of Stuart L Leviton by defendant Unicom Electric Inc re motion for order to preclude plaintiff EEOC from obtaining individual specific relief on behalf of any individual following the EEOC's failure to comply with the court's order re class member designation [48−1] and Exhibits (shb) (Entered: 10/22/2003)

NOTICE by defendant Unicom Electric Inc of lodging reporter's transcript (shb) (Entered: 10/22/2003)

SUPPLEMENTAL BRIEF by plaintiff in support of EEOC's motion to compel Defendant's responses to EEOC's Discovery Requests [42−1] (ir) (Entered: 10/23/2003)

DECLARATION of Elizabeth Esparza−Cervantes by plaintiff EEOC in support of Supplemental Brief in support of EEOC's motion to compel Defendant's responses to EEOC's Discovery Requests [42−1] (ir) (Entered: 10/23/2003)

PROOF OF SERVICE by defendant Unicom Electric Inc on 10/20/03 of Defendant's Notice of motion and motion to preclude Plaintiff EEOC from obtaining individual specific relief on behalf of any individual following the EEOC's failure to comply with the Court's Order regarding Class member designation; memorandum of points and authorities in support thereof (ir) (Entered: 10/23/2003)

PROOF OF SERVICE by defendant Unicom Electric Inc on 10/20/03 of Declaration of Stuart L Leviton and Exhibits thereto in support of Defendant's motion to preclude Plaintiff EEOC from obtaining individual Specific relief on behalf of any individual following the EEOC's failure to comply with the Court's Order regarding Class Member designation (ir) (Entered: 10/23/2003)

MINUTES (in chambers): that the motion to compel Defendant's responses to EEOC's Discovery Requests [42−1] is submitted; hearing scheduled for 10/28/03 is taken off calendar (see document for details); by Magistrate Judge Jennifer T. Lum CR: none present (ln) (Entered: 10/28/2003)

OPPOSITION by plaintiff EEOC to motion for order to preclude plaintiff EEOC from obtaining individual specific relief on behalf of any individual following the EEOC's failure to comply with the court's order re class member designation [48−1] (shb) (Entered: 10/28/2003)

DECLARATION of Elizabeth Esparza−Cervantes by plaintiff EEOC in support of opposition to motion for order to preclude plaintiff EEOC from obtaining individual specific relief on behalf of any individual following the EEOC's failure to comply with the court's order re class member designation [48−1] (shb) (Entered: 10/28/2003)

NOTICE OF WITHDRAWAL by defendant Unicom Electric Inc of its Fifth and Sixth Defenses in its First Amended Answer (ir) (Entered: 10/29/2003)

NOTICE OF MOTION AND MOTION by plaintiff EEOC for partial summary judgment ; motion hearing set for 10:00 11/24/03; Lodged Proposed Order and Uncontroverted Fact (ir) (Entered: 11/04/2003)

NOTICE by plaintiff EEOC of lodging Reporter's Transcipts to motion for partial summary judgment [60−1]; Lodged 3 Depositions (ir) (Entered: 11/04/2003)

DECLARATION of Elizabeth Esparza−Cervantes by plaintiff EEOC in support of its' motion for partial summary judgment [60−1] (ir) (Entered: 11/04/2003)

NOTICE OF MOTION AND MOTION by defendant Unicom Electric Inc for partial summary judgment ; motion hearing set for 10:00 11/24/03; memorandum of Points and Authorities in support thereof (ir) (Entered: 11/14/2003)

REPLY MEMORANDUM of Points and Authorities by defendant Unicom Electric Inc in support of motion for order to preclude plaintiff EEOC from obtaining individual specific relief on behalf of any individual following the EEOC's failure to comply with the court's order re class member designation [48−1] (ir) (Entered: 11/14/2003)

DECLARATION of Jeffrey Lo and Stuart Leviton by defendant Unicom Electric Inc in support of its' motion for partial summary judgment [74−1] (ir) (Entered: 11/14/2003)

NOTICE OF DISCREPANCY AND ORDER by Judge Christina A. Snyder ordering Defendant's Motion for summary judgment, declaration (2), memorandum and proposed statement of uncontroverted et al submitted by defendant Unicom Electric Inc received on 11/3/03 to be fld and processed; fld date to be the date the doc was stamped "received but not fld" w/the Clerk (ir) (Entered: 11/14/2003)

MINUTES: GRANT in part DENY in part Plaintiff's motion to compel Defendant's responses to EEOC's Discovery Requests [42−1] by Discovery Jennifer T. Lum CR: N/A (pj) (Entered: 11/10/2003)

SUPPLEMENTAL EXHIBITS by plaintiff EEOC to declaration of Elizabeth Esparza−Cervantes in support of EEOC's motion for partial summary judgment [60−1] (ir) (Entered: 11/12/2003)

PLACED IN FILE − NOT USED; Proposed Order regarding Plaintiff's motion to compel defendant's responses to EEOC's Discovery Requests; lodged 9/30/03 by Plaintiff Equal Employment Opportunity Commission (ir) (Entered: 11/12/2003)

MINUTES: Defendant's motion for order to preclude plaintiff EEOC from obtaining individual specific relief on behalf of any individual [48−1] (Filed 10/20/03) is DENIED IT IS SO ORDERED by Judge Christina A. Snyder CR: Laura Elias (ir) (Entered: 11/12/2003)

DECLARATION of Stuart L Leviton and Exhibits by defendant Unicom Electric Inc in support of Defendant's opposition to the EEOC's motion for partial summary judgment [60−1] (ir) (Entered: 11/12/2003)

STATEMENT of Genuine Issues of material fact by plaintiff EEOC in opposition to Defendant's motion for partial summary judgment as to Claimants Areas, Bell, Castillo, Preciado, Saddler, Valenzuela, Vega, Punitive damages and Backpay relief (ir) (Entered: 11/12/2003)

DECLARATION of Elizabeth Esparza−Cervantes by plaintiff EEOC in support of EEOC's opposition to Defendant's motion for partial summary judgment as to Claimants Areas, Bell, Castillo, Preciado, Saddler, Valenzuela, Vega, Punitive Damages, and Backpay Relief; Exhibits (ir) (Entered: 11/12/2003)

OPPOSITION by plaintiff EEOC to Defendant's motion for partial summary judgment; memorandum of Points and Authorities in support thereof; Declaration of Elizabeth Esparza−Cervantes and Exhibits (ir) (Entered: 11/12/2003)

STATEMENT of Genuine Issues by defendant Unicom Electric Inc in opposition to the EEOC's motion for partial summary judgment [60−1] (ir) (Entered: 11/12/2003)

OBJECTIONS filed by plaintiff EEOC to Evidence in Defendant's Statement of Uncontroverted Facts and Conclusions of law in support of Defendant's motion for partial summary judgment (ir) (Entered: 11/12/2003)

MINUTES: Settlement conference conducted off the record ; Settlement in principal has been reached and is recited on the record; Court has scheduled a telephonic follow−up stauts conference for 1:00 11/25/03, if necessary ; Counsel shall lodge a Stipulation of Dismissal by no later than 12/19/03; If Stipulation of Dismissal is not lodged by that date, counsel are ordered to contact the Court Clerk at 213−894−8285 to notify the Court why the settlement has not been finalized by Discovery Margaret A. Nagle CR: N/A (ir) (Entered: 11/20/2003)

NOTICE OF SETTLEMENT AND ORDER by Judge Christina A. Snyder Parties hearings set for 11/24/03 [74−1], [60−1] and all dates are hereby vacated (ir) (Entered: 11/24/2003)

STIPULATION and ORDER that the December 19, 2003 deadline to file the parties' settlement document is continued to January 16, 2003. No further continuances will be granted by Judge Christina A. Snyder terminating case (MD JS−6) (bp) (Entered: 12/23/2003)

ORDER DISMISSING ACTION. On November 21, 2003, the court received a notice of settlement filed by the parties. IT IS THEREFORE ORDERED that this action is dismissed without prejudice to reopening within 30 days from the date of this order if settlement is not consummated by Judge Christina A. Snyder dismissing case (MD JS−6) (shb) (Entered: 12/24/2003)

JOINT STIPULATION AND ORDER by Judge Christina A. Snyder : to reopen this action retroactive to 12/24/03 so that the Court can enter and the Consent Decree by Judge Christina A. Snyder. (Made JS−5, Case reopened), (ir, ) (Entered: 01/12/2004)

CONSENT DECREE by Judge Christina A. Snyder: Parties agree that this Decree resolves all claims arising out of EEOC Charge Nos 340A01305, 340A01306, and 340A01307 and the complaint filed in this action. Duration of this Decree shall be three (3) years from the date of entry of the Decree. In settlement of all monetary claims of Marie Younger, Adriana Preciado, Marc Sorko−Ram, Marina Areas, Mary Bell, Alicia Castillo, Eric Moore, Kaife Saddler, Lourdes Valenzuela, and Alfredo Vega other than attorneys' fees and costs, Defendants agrees to pay a total of Three Hundred Fifty Thousand Dollars ($350,000.00) to be distributed among these individuals by the EEOC at its discretion. Defendant shall pay the total amount as follows: $100,000 within 30 days of entry of this Consent Decree and $50,000 each month thereafter for a payment total of $350,000. Within thirty (30 days of the Court's entry of this Consen Decree the EEOC shall provide in writing to Defendant the specific monetary distribution that is to be provided to each of the Charging Parties and Class Members. (See document for further details) (MD JS−6)(ir, ) (Entered: 01/12/2004)

NOTICE AND REQUEST of Settlement Procedure Selection (Sp2) filed; Parties request to appear before an attorney selected by the Attorney Settlement Officer Panel or appointed by the Judge for Settlement Proceedings; Settlement procedure selection request Granted By Order of Christina A. Snyder (ir, ) (Entered: 01/12/2004)

SETTLEMENT POSTING AND ORDER regarding Consent Decree by Judge Christina A. Snyder (See document for further details)(ir, ) (Entered: 01/23/2004)