Case: EEOC v. AREA ERECTORS, INC.

EEOC v. Area Erectors Inc.

EEOC v. Area Erectors, Inc.

U.S. District Court for the Northern District of Illinois

EEOC v. Area Erectors Inc.

Equal Employment Opportunity Commission v. Area Erectors, Inc.

EEOC v. Area Erectors Inc.

U.S. District Court for the Northern District of Illinois

EEOC v. Area Erectors Inc.

U.S. District Court for the Northern District of Illinois

Equal Employment Opportunity Commission v. Area Erectors, Inc.

U.S. District Court for the Northern District of Illinois

Carly Knight, Frank Dobbin, Alexandra Kalev

COMPLAINT filed by Equal Employment Opportunity Commission; Jury Demand. (to view an image of this document see entry number 32).(vkd, ) (Entered: 05/02/2007)

ANSWER and Affirmative Defenses by Defendant Area Erectors, Inc. (To view an image of this document see entry number 32).(vkd, ) (Entered: 05/02/2007)

INTERVENOR complaint filed by Giles L. Jefferson against Area Erectors, Inc. (To view an image of this document see entry number 32).(vkd, ) (Entered: 05/02/2007)

ANSWER to Intervenor Complaint by Area Erectors, Inc. (To view an image of this document see entry number 32).(vkd, ) (Entered: 05/02/2007)

ANSWER AMENDED to Complaint in Intervention by Defendant Area Erectors, Inc.(To view an image of this document see entry number 32). (vkd, ) (Entered: 05/02/2007)

RECEIVED from USDC Western District of Wisconsin; the transfer record consisting of transmittal letter, certified copy of docket sheet and transfer order. Case No. 06−C−0516−C (Attachments: # 1 Complaint# 2 answer to complaint# document# 4 (3) intervenor complaint# document# 10(4) answer to intervenor complaint# document #15 (5) answer − amd cmp in intervention document #26) (vkd, ) (Entered: 05/02/2007)

CIVIL Cover Sheet (vkd, ) (Entered: 06/07/2007)

MINUTE entry before Judge Charles P. Kocoras :Status hearing set for 6/5/2007 at 09:30 AM. At the initial hearing, parties to report on the following: 1. Possibility of settlement. 2. If no possibility of settlement exists, the nature and length of discovery necessary to prepare the case for resolution. Plaintiff is directed to advise all other parties of the Court's action herein. Lead counsel for each party is required to attend the initial hearing.Mailed notice (sct, ) (Entered: 05/17/2007)

ATTORNEY Appearance for Defendant Area Erectors, Inc. by James D. Zeglis. (vkd, ) (Entered: 05/24/2007)

STIPULATION (Joint) to Transfer (Attachments: # 1 Certificate of Service)(Cummings, Jeffrey) (Entered: 06/01/2007)

MINUTE entry before Judge Charles P. Kocoras :Parties having stipulated to the transfer of this case to the Western Division, status hearing set for 6/5/2007 is stricken.Telephone notice (sct, ) (Entered: 06/04/2007)

MINUTE entry before Judge Charles P. Kocoras : Pursuant to the parties' Joint Stipulation to Transfer 35 , order cause transferred to the United States District Court for the Northern District of Illinois, Western Division. Mailed notice (vkd, ) (Entered:

APPLICATION for Leave to Appear Pro Hac Vice on behalf of Area Erectors, Inc. by Bradley G. Kennedy; Order entered granting leave by Judge Charles P. Kocoras. Filing fee $50 paid, receipt number 10910077. (vkd, ) (Entered: 06/07/2007)

APPLICATION for Leave to Appear Pro Hac Vice on behalf of Area Erectors, Inc. by David Minko; Order entered granting leave by Judge Charles P. Kocoras. Filing fee $50 paid, receipt number 10910077. (vkd, ) (Entered: 06/07/2007)

APPLICATION for Leave to Appear Pro Hac Vice on behalf of Area Erectors, Inc. by Jonathan P. Bruni; Order entered granting leave by Judge Charles P. Kocoras. Filing fee $50 paid, receipt number 10910077. (vkd, ) (Entered: 06/07/2007)

APPLICATION for Leave to Appear Pro Hac Vice on behalf of Area Erectors, Inc. by Daniel D Barker; Order entered granting leave by Judge Charles P. Kocoras. Filing fee $50 paid, receipt number 10910077. (vkd, ) (Entered: 06/07/2007)

MOTION to quash or Modify Subpoena (Eisenberg, Nathan) (Entered: 06/07/2007)

NOTICE of Motion by Nathan D Eisenberg for presentment of motion to quash 39 before Honorable Charles P. Kocoras on 7/3/2007 at 09:30 AM. (Eisenberg, Nathan) (Entered: 06/07/2007)

MEMORANDUM by Iron Workers Local No. 8 in support of motion to quash 39 or Modify Subpoena (Attachments: # 1 Certificate of Service)(Eisenberg, Nathan) (Entered: 06/07/2007)

AFFIDAVIT of Matthew R. Robbins by Iron Workers Local No. 8 regarding motion to quash 39 (Attachments: # 1 Exhibit Attachment A to Defendant's Subpoena dated 5/7/07 to Ironworkers Local 8)(Eisenberg, Nathan) (Entered: 06/07/2007)

MOTION to quash or Modify Subpoena (Eisenberg, Nathan) (Entered: 06/07/2007)

NOTICE of Motion by Nathan D Eisenberg for presentment of motion to quash 43 before Honorable Charles P. Kocoras on 7/3/2007 at 09:30 AM. (Eisenberg, Nathan) (Entered: 06/07/2007)

MEMORANDUM by Ironworkers Local No. 383 in support of motion to quash 43 or Modify Subpoena (Attachments: # 1 Certificate of Service)(Eisenberg, Nathan) (Entered: 06/07/2007)

AFFIDAVIT of Matthew R. Robbins by Ironworkers Local No. 383 (Attachments: # 1 Exhibit Attachment A to Defendant's Subpoena dated 5/7/07 to Ironworkers Local 383)(Eisenberg, Nathan) (Entered: 06/07/2007)

INTRA district transfer from the Eastern Division. Case assigned to Judge Philip G. Reinhard and P. Michael Mahoney for all further proceedings. Western Division received a Transfer Letter. (jat, ) Modified on 6/11/2007 (jat, ). (Entered: 06/08/2007)

THIS matter is referred to the Hon. P. Michael Mahoney pursuant to Internal Operating Procedure 11(d). (jat, ) (Entered: 06/08/2007)

MINUTE entry before Judge Charles P. Kocoras :This cause having been transferred to the Western Division, all hearings set before Judge Kocoras are hereby stricken. Mailed notice (sct, ) (Entered: 06/11/2007)

ATTORNEY Appearance for Plaintiff Equal Employment Opportunity Commission by Ann M Henry (Henry, Ann) (Entered: 06/11/2007)

MINUTE entry before Judge P. Michael Mahoney :Status hearing set for 6/20/2007 at 01:30 PM.Mailed notice (glg, ) (Entered: 06/12/2007)

MOTION by Plaintiff Equal Employment Opportunity Commission for protective order (Attachments: # 1 Exhibit Proposed Protective Order)(Henry, Ann) (Entered: 06/18/2007)

REPORT of Rule 26(f) Planning Meeting by Equal Employment Opportunity Commission (Henry, Ann) (Entered: 06/18/2007)

MINUTE entry before Judge P. Michael Mahoney : Status hearing held. Plaintiff's application for Deborah Powers to appear pro hac vice is granted. Plaintiff's agreed motion for protective order 56 is granted. Case management order approved as stated. FRCP 26(a)(1) disclosure exchanged. Plaintiffs' FRCP 26(a)(2) expert disclosure due October 1, 2007. Defendant's FRCP 26(a)(2) expert disclosure due November 1, 2007. Depositions by December 31, 2007. Defendants given 20 depositions. Depositions limited to 4 hours. Amended pleadings due July 10, 2007. All discovery closed December 31, 2007. Dispositive motions due February 4, 2008. Discovery conference to set ADR set for August 29,2007 at 1:30 pm. [ For further detail see separate order(s).] (jat, ) (Entered: 06/21/2007)

APPLICATION for Leave to Appear Pro Hac Vice on behalf of Equal Employment Opportunity Commission by Deborah J. Powers; Order entered granting leave by Judge P. Michael Mahoney. (jat, ) (Entered: 06/21/2007)

Agreed PROTECTIVE Order Signed by Judge P. Michael Mahoney on 6/20/2007:(jat, ) (Entered: 06/21/2007)

MOTION by Defendant Area Erectors, Inc. for joinder of Certain Local Unions (Attachments: # 1 Notice of Filing # 2 Affidavit of Daniel D. Barker# 3 Affidavit of Steve Schrader# 4 Text of Proposed Order # 5 Certificate of Service)(Barker, Daniel) (Entered: 07/10/2007)

MEMORANDUM by Area Erectors, Inc. in support of motion for joinder, 62 of Certain Local Unions (Barker, Daniel) (Entered: 07/10/2007)

MEMORANDUM by Equal Employment Opportunity Commission in Opposition to motion for joinder, 62 (Powers, Deborah) (Entered: 07/13/2007)

DECLARATION of Deborah J. Powers regarding memorandum in opposition to motion 64 by Equal Employment Opportunity Commission (Attachments: # 1 Exhibit A# 2 Exhibit B)(Powers, Deborah) (Entered: 07/13/2007)

CERTIFICATE of Service by Plaintiff Equal Employment Opportunity Commission regarding memorandum in opposition to motion 64 (Powers, Deborah) (Entered: 07/13/2007)

REPLY by Area Erectors, Inc. to memorandum in support of motion 63 , memorandum in opposition to motion 64 , MOTION by Defendant Area Erectors, Inc. for joinder of Certain Local Unions 62 (Barker, Daniel) (Entered: 07/16/2007)

CERTIFICATE of Service by Defendant Area Erectors, Inc. regarding reply to response to motion 67 (Barker, Daniel) (Entered: 07/16/2007)

STIPULATION to withdraw motion to join Ironworkers Local 383 (Barker, Daniel) (Entered: 07/17/2007)

MINUTE entry before Judge P. Michael Mahoney : Defendant's Motion for joinder 62 is taken under advisement; Magistrate Judge will rule. (glg, ) (Entered: 07/18/2007)

MINUTE entry before Judge P. Michael Mahoney :Defendant's Motion to Join Certain Local Unions as Non−Aligned Parties 62 is granted in part. Int'l Union of Operating Engineers Locals 150, 139, & 649, and Ironworkers Locals 112, 380, 393, & 498 are joined as non−aligned parties. Defendant is to effect service of process on these unions. [For further details see text below.]judge's staff mailed notice (jat, ) (Entered: 07/25/2007)

AMENDED complaint by Equal Employment Opportunity Commission against all defendants (Powers, Deborah) (Entered: 08/09/2007)

CERTIFICATE of Service by Plaintiff Equal Employment Opportunity Commission regarding amended complaint 72 (Powers, Deborah) (Entered: 08/09/2007)

ANSWER to Complaint (First Amended) by Area Erectors, Inc.(Barker, Daniel) (Entered: 08/23/2007)

CERTIFICATE of Service by Defendant Area Erectors, Inc. (Barker, Daniel) (Entered: 08/23/2007)

ATTORNEY Appearance for Intervenor Plaintiff Giles L. Jefferson by Tiffany Fonseca Glanville (Attachments: # 1 Certificate of Service)(Glanville, Tiffany) (Entered: 08/28/2007)

MINUTE entry before Judge P. Michael Mahoney :Discovery hearing held on 8/29/2007. Discovery Hearing to set ADR and new discovery schedule set for 11/7/2007 at 01:30 PM. (glg, ) (Entered: 08/29/2007)

ANSWER to amended complaint by Ironworkers Local 393(Fioretto, Pasquale) (Entered: 09/10/2007)

ATTORNEY Appearance for Unknown Ironworkers Local 393 by Pasquale Angelo Fioretto (Fioretto, Pasquale) (Entered: 09/10/2007)

ATTORNEY Appearance for Unknown Ironworkers Local 393 by Brian C. Hlavin (Hlavin, Brian) (Entered: 09/10/2007)

ANSWER to amended complaint by Ironworkers Local 498(Fioretto, Pasquale) (Entered: 09/10/2007)

ATTORNEY Appearance for Unknown Ironworkers Local 498 by Pasquale Angelo Fioretto (Fioretto, Pasquale) (Entered: 09/10/2007)

ATTORNEY Appearance for Unknown Ironworkers Local 498 by Brian C. Hlavin (Hlavin, Brian) (Entered: 09/10/2007)

ANSWER to amended complaint by Int'l Union of Operating Engineers Local 139(Hlavin, Brian) (Entered: 09/10/2007)

ATTORNEY Appearance for Unknown Int'l Union of Operating Engineers Local 139 by Brian C. Hlavin (Hlavin, Brian) (Entered: 09/10/2007)

ATTORNEY Appearance for Unknown Int'l Union of Operating Engineers Local 139 by Pasquale Angelo Fioretto (Fioretto, Pasquale) (Entered: 09/10/2007)

ANSWER to amended complaint by Ironworkers Local 112(Marco, Frank) (Entered: 09/18/2007)

ANSWER to amended complaint by Ironworkers Local 380(Marco, Frank) (Entered: 09/18/2007)

ATTORNEY Appearance for Unknown Int'l Union of Operating Engineers Local 150 by Dale D. Pierson (Pierson, Dale) (Entered: 09/27/2007)

MOTION by Unknown Int'l Union of Operating Engineers Local 150 for extension of time to file answer or otherwise plead (Agreed) (Pierson, Dale) (Entered: 09/27/2007)

ATTORNEY Appearance for Unknown Int'l Union of Operating Engineers Local 150 by Charles R Kiser (Kiser, Charles) (Entered: 09/27/2007)

MOTION by Plaintiff Equal Employment Opportunity Commission for protective order (Attachments: # 1 Exhibit A−F)(Powers, Deborah) (Entered: 09/28/2007)

NOTICE of Motion by Deborah J. Powers for presentment of motion for protective order 93 before Honorable P. Michael Mahoney on 10/10/2007 at 01:30 PM. (Powers, Deborah) (Entered: 09/28/2007)

MINUTE entry before Judge P. Michael Mahoney : Defendant's Motion for extension of time to answer 91 is granted. Response to complaint due by 10/22/2007.Mailed notice (glg, ) (Entered: 10/03/2007)

DOCUMENT ENTERED IN ERROR(Barker, Daniel) Modified on 10/4/2007 (gcy, ). (Entered: 10/03/2007)

Notice of Motion to Compel NOTICE of Motion by Daniel D Barker for presentment of before Honorable P. Michael Mahoney on 10/10/2007 at 01:30 PM. (Barker, Daniel) (Entered: 10/03/2007)

MOTION by Defendant Area Erectors, Inc. to compel Discovery (Attachments: # 1)(Barker, Daniel) (Entered: 10/03/2007)

MEMORANDUM of Law in Support of Motion to Compel Discovery (Barker, Daniel) (Entered: 10/03/2007)

RE−MOTION by Defendant Area Erectors, Inc. to dismiss Operating Engineer Local 649 as a Non−Aligned Party (Attachments: # 1 # 2)(Barker, Daniel) Modified on 10/4/2007 (gcy, ). (Entered: 10/04/2007)

CORRECTED NOTICE of Motion by Daniel D Barker for presentment of motion to dismiss 96 , motion to dismiss 101 before Honorable P. Michael Mahoney on 10/10/2007 at 01:30 PM. (Barker, Daniel) Modified on 10/4/2007 (gcy, ). (Entered: 10/04/2007)

RESPONSE by Equal Employment Opportunity Commissionin Opposition to MOTION by Defendant Area Erectors, Inc. to compel Discovery 99 (Henry, Ann) (Entered: 10/09/2007)

MINUTE entry before Judge P. Michael Mahoney : As stated in open court. Defendant Area Erectors' motion to dismiss Operating Engineers Local 649 as a non−aligned party 96 101 is granted. Plaintiff's motion for protective order 93 and Defendant's motion to compel 99 are taken under advisement. Responses due 10/17/2007. Replies due 10/26/2007. If a party is not going to file a brief in response or reply, it is that party's obligation, within the time frame established by this order, to so notify the court in writing. Magistrate Judge will rule.Docketing mailed notice (pg, ) (Entered: 10/10/2007)

Letter to Magistrate P. Michael Mahoney in response to Court Order entered 10/10/07 by Int'l Union of Operating Engineers Local 139 (Fioretto, Pasquale) (Entered: 10/15/2007)

CERTIFICATE of Service by Pasquale Angelo Fioretto on behalf of Int'l Union of Operating Engineers Local 139 regarding other 105 (Fioretto, Pasquale) (Entered: 10/15/2007)

Letter to Magistrate P. Michael Mahoney in response to Court Order entered 10/10/07 by Ironworkers Local 393 (Fioretto, Pasquale) (Entered: 10/15/2007)

CERTIFICATE of Service by Pasquale Angelo Fioretto on behalf of Ironworkers Local 393 regarding other 107 (Fioretto, Pasquale) (Entered: 10/15/2007)

Letter to Magistrate P. Michael Mahoney in response to Court Order entered 10/10/07 by Ironworkers Local 498 (Fioretto, Pasquale) (Entered: 10/15/2007)

CERTIFICATE of Service by Pasquale Angelo Fioretto on behalf of Ironworkers Local 498 regarding other 109 (Fioretto, Pasquale) (Entered: 10/15/2007)

Letter to Magistrate Judge Mahoney re 10/10/07 order by Giles L. Jefferson (Attachments: # 1 Certificate of Service)(Glanville, Tiffany) (Entered: 10/16/2007)

Letter to Magistrate Judge Mahoney in response to Court Order entered 10/10/07 by Int'l Union of Operating Engineers Local 150 (Kiser, Charles) (Entered: 10/17/2007)

MEMORANDUM by Area Erectors, Inc. in support of motion to compel 99 (Supplemental) (Barker, Daniel) (Entered: 10/17/2007)

CERTIFICATE of Service by Defendant Area Erectors, Inc. regarding memorandum in support of motion 113 (Barker, Daniel) (Entered: 10/17/2007)

ANSWER to amended complaint by Int'l Union of Operating Engineers Local 150(Pierson, Dale) (Entered: 10/22/2007)

MEMORANDUM by Equal Employment Opportunity Commission in support of motion for protective order 93 supplemental (Attachments: # 1 Exhibit A − D)(Powers, Deborah) (Entered: 10/25/2007)

ATTORNEY Appearance for Unknown Int'l Union of Operating Engineers Local 150 by Robert Glenn Reiter, Jr (Reiter, Robert) (Entered: 11/06/2007)

MINUTE entry before Judge P. Michael Mahoney :Discovery hearing held on 11/7/2007. Settlement Conference set for 12/17/2007 at 01:30 PM. Real parties in interest to be present. Parties to submit a 3 page settlement document to chambers by 12/14/07. Mailed notice (glg, ) (Entered: 11/07/2007)

Signed by Judge P. Michael Mahoney on 11/27/2007: Plaintiff's motion for a protective order 93 and Defendant's motion to compel 99 are granted in part as stated in the attached Memorandum Opinion and Order. [For further details see separate order(s).]Notices mailed by Judicial Staff notice (Attachments: # 1 MEMORANDUM OPINION & ORDER)(pg, ) (Entered: 11/27/2007)

MINUTE entry before Judge P. Michael Mahoney :Settlement conference held on 12/17/2007. Parties to hold Rule 26 Meeting. Case management order due by 1/22/2008. Initial Pretrial Conference set for 1/23/2008 at 01:30 PM. (glg, ) (Entered: 12/17/2007)

Proposed Revised Case Management Order by Area Erectors, Inc. (Barker, Daniel) (Entered: 01/21/2008)

MINUTE entry before Judge P. Michael Mahoney : Pursuant to request of counsel, Initial Pretrial Conference reset as to time only, for 1/23/2008 at 10:30 AM. Conference to be heard telephonically. Telephoned notice (glg, ) (Entered: 01/22/2008)

MINUTE entry before Judge P. Michael Mahoney :Telephonic Initial Pretrial conference held on 1/23/2008. Case management order approved. Plaintiff's FRCP 26(a)(2) expert disclosure due 10/2/08. Defendant's FRCP 26(a)(2) expert disclosure due 11/3/08. Rubuttal FRCP 26(a)(2) expert disclosure due 11/24/08. Expert depositions held by 12/31/08. Fact Discovery ordered closed by 9/2/2008. Dispositive Motions due by 11/3/2008. Telephonic Discovery Hearing set for 3/12/2008 at 10:30 AM. Settlement Conference set for 3/27/2008 at 10:30 AM. Parties to submit 2 page update on settlement to chambers by 3/26/08. Real parties in interest to be present. Telephoned notice (glg, ) (Entered: 01/23/2008)

MINUTE entry before Judge P. Michael Mahoney : Third−party Iron Workers Local 383 filed two motions to quash or modify plaintiff's subpoena on 6/7/07 39 , 43 . Because these motions were not noticed up pursuant to Local Rule 5.3, they are hereby dismissed without prejudice. Notices mailed by Judicial staff. (jat, ) (Entered: 02/15/2008)

MINUTE entry before Judge P. Michael Mahoney : Telephonic Discovery hearing held on 3/12/2008. Pursuant to request of counsel, Settlement Conference reset for 4/22/2008 at 10:30 AM. Same procedures to be followed as set forth in order of 1/23/08. Telephoned notice (glg, ) (Entered: 03/12/2008)

MINUTE entry before Judge Honorable P. Michael Mahoney:Settlement conference held on 4/22/2008. Settlement Conference set for 6/26/2008 at 10:30 AM. (glg, ) (Entered: 04/22/2008)

MINUTE entry before the Honorable P. Michael Mahoney:Settlement conference held. Status hearing set for 8/13/08 at 1:30 PM. Notices mailed by Judicial staff. (jat, ) (Entered: 06/27/2008)

NOTICE by Ann M Henry of Change of Address (Henry, Ann) (Entered: 07/08/2008)

MINUTE entry before the Honorable P. Michael Mahoney:Status hearing held on 8/13/2008. By agreement, intervenor Jefferson may serve discovery on the union. Status hearing to set new discovery schedule, if necessary, set for 10/15/2008 at 01:30 PM. (glg, ) (Entered: 08/13/2008)