Case: Hnot v. Willis Group Holdings

U.S. Court of Appeals for the Second Circuit

CLASS ACTION COMPLAINT filed. Summons issued and Notice pursuant to 28 U.S.C. 636(c). FILING FEE $ 150.00 RECEIPT # 412007. (jco) Modified on

FIRST AMENDED COMPLAINT by Shelley Hnot, Maria Traverso, Teresa Jimenez, Margaret Mahon, Heidi Scheller (Answer due 10/15/01 for Willis North, for Willis Group ); amending [1−1] complaint; Summons issued. (pl) (Entered: 10/04/2001)

DEMAND for jury trial by Shelley Hnot, Maria Traverso, Teresa Jimenez, Margaret Mahon, Heidi Scheller . (pl) (Entered: 10/04/2001)

WAIVER OF SERVICE of summons returned executed as to Willis Group, Willis North mailed on 10/5/01 . Answer due on 12/4/01 for Willis Group, for Willis North . (bai) (Entered: 10/19/2001)

NOTICE OF MOTION by Shelley Hnot, Maria Traverso, Teresa Jimenez, Margaret Mahon, Heidi Scheller for an order, purs. to Rule 1.3(c) of the Local Civil Rules, admitting Christine E. Webber pro hac vice on behalf of pltffs . No return date indicated. Affidavits of Susan R. Schwaiger, and of Christine E. Webber; and proposed order are attached. (sn) (Entered: 12/28/2001)

STIPULATION and ORDER, reset answer to complaint due for 1/8/02 for Willis North, for Willis Group . ( signed by Judge Gerard E. Lynch ) (ae) (Entered: 12/27/2001)

ORDER; granting [5−1] motion for an order, purs. to Rule 1.3(c) of the Local Civil Rules, admitting Christine E. Webber pro hac vice on behalf of pltffs . ( signed by Judge Gerard E. Lynch ); Copies mailed. (docmt forwarded to atty admissions clerk) (djc) (Entered: 01/09/2002)

RULE 1.9 CERTIFICATE filed by Willis Group, Willis North . (bai) (Entered: 01/10/2002)

ANSWER TO THE FIRST AMENDED COMPLAINT by Willis Group, Willis North (Attorney Bettina B. Plevan from the Firm: Proskauer Rose LLP). (bai) (Entered: 01/10/2002)

NOTICE OF MOTION by Shelley Hnot, Maria Traverso for an order pursuant to Rule 1.3 of the Local Rules of USDC/SDNY admitting Jessica Glick Lyn to appear pro hac vice as counsel for palintiffs . Return date not indicated. Declaration of Susan R. Schwaiger in support attached with Affidavit of Jessica G. Lyn in support of motion attached. (bai) (Entered: 01/10/2002)

AMENDED CERTIFICATE OF SERVICE of Notice of pro hac vice motion by First−class mail on 1/9/02 to Bettina B. Plevan, Esq., of Proskauer Rose LLP. (djc) (Entered: 01/11/2002)

AMENDED ANSWER to Complaint by Willis Group, Willis North: amends [8−1] complaint answer. (jco) (Entered: 01/31/2002)

ORDER; that Joseph M. Sellers is hereby granted admission pro hac vice ot hte U.S.D.C. for the S.D.N.Y., for the purpose of appearing in this action, pursuant to Rule 1.3(c) of the Local Rules of the U.S.D.C. for the S.D. N.Y.; Joseph M. Sellers is required to notify the Court immediately of any matter that affects his standing at the Bar of any court . ( signed by Judge Gerard E. Lynch ); Copies mailed; forwarded this document to the Attorney Admission Clerk. (pl) (Entered: 02/04/2002)

ORDER; Joseph M. Sellers is granted admission pro hac vice for the purpose of appearing in this action purs. to Rule 1.3(c) of the Local Rules, SDNY . ( signed by Judge Gerard E. Lynch ); Copies mailed. (Forwarded to Attorney Admissions Clerk) (sn) (Entered: 02/04/2002)

STIPULATION and ORDER; regarding procedures to be followed that shall govern the handling of "confidential materials" . ( signed by Judge Gerard E. Lynch ) (jco) (Entered: 07/03/2002)

ORDER; That at the 9/11/02 ptrlcnf the Court granted the [9−1] motion for an order pursuant to Rule 1.3 of the Local Rules of USDC/SDNY admitting Jessica Glick Lyn to appear pro hac vice as counsel for pltffs. ( signed by Judge Gerard E. Lynch ); Copies mailed. (tp) Modified on 08/06/2002 (Entered: 08/05/2002)

ORDER, for Jessica Glick to appear pro hac vice . ( signed by Judge Gerard E. Lynch ); Copies mailed. (Sent to the Attorney Admissions Clerk). (kw) (Entered: 08/09/2002)

NOTICE OF MOTION by Shelley Hnot, Maria Traverso, Teresa Jimenez, Margaret Mahon, Heidi Scheller to compel discovery of Nationwide Computerized Database ; Return Date not indicated. (djc) (Entered: 09/13/2002)

STIPULATION and ORDER; regarding amending the caption of this action and amending the complaint . ( signed by Judge Gerard E. Lynch ) (pl) (Entered: 11/22/2002)

Case Management Plan: date by which pltffs may file motions to join additional parties or amend pleading: 12/31/02. Date by which dft s will produce copies of written complaints of sex discrimination: 11/22/02. Date by which dfts will produce computerized employee database for the Northeast region: 12/3/02. Date by which all non−expert discovery is to be completed: 9/30/03. Date by which class certification experts, if any, will be designated by the parties: 6/15/03 these reports will be exchanged simultaneously by the parties: 8/1/03. A status conference will be held on 9/26/03 at 10:00 a.m. All other procedures and deadlines are as further set forth in said order. ( signed by Judge Gerard E. Lynch ) (db) (Entered: 12/04/2002)

ORDER; denying [17−1] motion to compel discovery of Nationwide Computerized Database. For the reasons stated on the record at a conference before the Court on 11/13/02, this motion was effectively denied without prejudice to renew. As such, the Clerk of the Court is respectfully directed to close out this motion in all internal reports. ( signed by Judge Gerard E. Lynch ); (jco) (Entered: 12/06/2002)

Transcript of record of proceedings before Judge Gerard E. Lynch for the date(s) of 11/13/02. (dt) (Entered: 01/02/2003)

STIPULATION and ORDER, defendants are permitted to serve and file the attached Second Amended Answer to the First Amended Complaint ; ( signed by Judge Gerard E. Lynch ); (docmt not attached) (djc) (Entered: 10/27/2003)

SECOND AMENDED ANSWER by Willis Group, Willis North, Willis of New York, Willis of New Jersey and Willis of Massachusetts to [2−1] amended complaint. (Attorney Myron D. Rumeld, Bettina B. Plevan from the Firm: Proskauer, Rose, L.L.P.). (db) Modified on 10/28/2003 (Entered: 10/28/2003)

Revised Case Management Plan: Non−expert discovery is to be completed by 2/28/04. (See document for further related discovery schedule). ( signed by Judge Gerard E. Lynch ); (kw) (Entered: 11/09/2003)

RESPONSE by Willis Group, Willis North to [17−1] motion to compel discovery of Nationwide Computerized Database (yv) (Entered: 11/22/2003)

AFFIDAVIT of Joan Gustafson Haworth, Ph.D. by Willis Group, Willis North. (yv) (Entered: 11/22/2003)

AFFIDAVIT of Kristin S. Rozic by Willis Group, Willis North in support of [25−1] motion response . (yv) (Entered: 11/22/2003)

REPLY in support to Motion re: 17 Motion to Compel. Document filed by Shelley Hnot, Teresa Jimenez, Margaret Mahon, Heidi Scheller, Maria Traverso. (pl, ) (Entered: 12/03/2003)

Offer of Judgment. Document filed by Willis Group Holdings Ltd., Willis North America Inc. (yv, ) (Entered: 12/23/2003)

Offer of Judgment. Document filed by Willis Group Holdings Ltd., Willis North America Inc. (yv, ) (Entered: 12/23/2003)

Acceptance of Offer of Judgment. Document filed by Teresa Jimenez. (yv, ) (Entered: 12/23/2003)

ORDER/Acceptance of Offer of Judgment: plaintiff Maria accepts the Offer of Judgment made by defendants in the amount of $75,000. (Signed by Judge Gerard E. Lynch on 12/9/03) (kw, ) (Entered: 01/21/2004)

NOTICE of plaintiffs Renewed request to compel discovery of Nationwide computerized database. Document filed by Shelley Hnot, Teresa Jimenez, Margaret Mahon, Heidi Scheller, Maria Traverso. (kw, ) (Entered: 01/08/2004)

ORDER The plaintiffs' renewed motion to compel discovery of a nationwide computerbase is denied. The Clerk of Court is respectfully requested to close out that motion (Dkt. No. 33) on internal reports. Plaintiffs' motion for class certification shall be submitted by 6/1/2004; defendants' opposition shall be submitted by 8/3/2004; plaintiffs' reply shall be submitted by 9/3/2004. (Signed by Judge Gerard E. Lynch on 1/9/2004) (jsa). (Entered: 01/27/2004)

Set Deadlines/Hearings: (See doc. #35) Plaintiff's motion for class certification due by 6/1/2004. Defendants' opposition due by 8/3/2004. Plaintiffs' reply due by 8/3/2004 (ae, ) (Entered: 01/29/2004)

JUDGMENT #04,0496 in favor of plaintiff, Maria Traverso and against defendants Willis Group et.al., in the amount of $ 75,000. (Signed by Judge Gerard E. Lynch on 03/9/04) (jf, ) (Entered: 03/16/2004)

JUDGMENT #04,0497 in favor of plaintiff, Teresa Jimenez against defendants in the amount of $ 75,000. (Signed by Judge Gerard E. Lynch on 03/09/04) (jf, ) (Entered: 03/16/2004)

Mailed notice of Right to Appeal to Attorney(s) of Record: Martin R. Lee, Jessica Glick Lyn, Linda P. Nussbaum, Bettina Barasch Plevan, Myron D. Rumeld. (snu) (Entered: 03/17/2004)

TRANSCRIPT of proceedings held on January 9, 2003 before Judge Gerard E. Lynch.(djc, ) (Entered: 03/19/2004)

ORDER, regarding issues concerning the parties' joint submission dated 3/15/04 granting an additional three hours of deposition. (Signed by Judge Gerard E. Lynch on 3/24/04) (tp, ) (Entered: 04/01/2004)

STIPULATION AND ORDER, that plntf Mahon will not provide a declaration etc re plntfs' motion for class certification, if any, as further set forth in this document. (Signed by Judge Gerard E. Lynch on 5/10/04) (cd, ) (Entered: 05/12/2004)

ENDORSED LETTER addressed to Judge Lynch from Christine E. Webber dated 5/17/2004 re: extension of deadine for motion for class certification be extended to 6/11/2004. Defendants opposition due on 8/20/2004 and plaintiff's reply due on 9/20/2004. Request granted. (Signed by Judge Gerard E. Lynch on 5/18/2004) (jsa, ) (Entered: 05/21/2004)

Set Deadlines/Hearings: Motions due by 6/11/2004. Replies due by 9/20/2004. Responses due by 8/20/2004 (jsa, ) (Entered: 05/21/2004)

MEMORANDUM OF LAW in Support Of Plaintiffs' Motion For Leave To Amend The Complaint. Document filed by Shelley Hnot, Teresa Jimenez, Margaret Mahon, Heidi Scheller, Maria Traverso. (jmi, ) (Entered: 06/08/2004)

MOTION For Leave to Amend/Correct Complaint. Document filed by Shelley Hnot, Teresa Jimenez, Margaret Mahon, Heidi Scheller, Maria Traverso. (jmi, ) (Entered: 06/08/2004)

MOTION to Certify Class; attached are papers in support. Document filed by Shelley Hnot, Teresa Jimenez, Margaret Mahon, Heidi Scheller. (cd, ) (Entered: 06/16/2004)

MEMORANDUM OF LAW in Support re: 44 MOTION to Certify Class.. Document filed by Shelley Hnot, Teresa Jimenez, Margaret Mahon, Heidi Scheller, Maria Traverso. (cd, ) (Entered: 06/16/2004)

CERTIFICATE OF SERVICE of Affidavit of Jeremy M. Brown served on plaintiffs' counsel on 6/15/04. Service was made by MAIL. Document filed by Shelley Hnot, Margaret Mahon, Heidi Scheller. (jco, ) (Entered: 06/17/2004)

ENDORSED LETTER addressed to Judge Lynch from Christine Webber dated 6/14/04: granting plntf's request for leave to submit a memo of 33 pages, instead of 25 pages established by your standing rules. (Signed by Judge Gerard E. Lynch on 6/15/04) (cd, ) (Entered: 06/24/2004)

MEMORANDUM OF LAW in Opposition re: 43 MOTION to Amend/Correct.. Document filed by Willis Group Holdings Ltd., Willis North America Inc.. (jmi, ) (Entered: 07/07/2004)

AFFIDAVIT of Jeremy M. Brown, ESQ. in Support Of Defendants' Opposition To Plaintiffs' re: 43 MOTION to Amend/Correct.. Document filed by Willis Group Holdings Ltd., Willis North America Inc.. (jmi, ) (Entered: 07/07/2004)

REPLY MEMORANDUM OF LAW in Support of 43 MOTION to Amend/Correct. Document filed by Shelley Hnot, Margaret Mahon, Heidi Scheller. (db, ) (Entered: 07/08/2004)

DECLARATION of Christine Webber. Document filed by Shelley Hnot, Margaret Mahon, Heidi Scheller. (db, ) (Entered: 07/08/2004)

MOTION for an Order pursuant to F.R.C.P. granting Summary Judgment. Document filed by Willis Group Holdings Ltd., Willis North America Inc. (jco, ) (Entered: 07/16/2004)

MEMORANDUM AND OPINION # 90470; for the reasons set forth on this Opinion, pltffs motion to amend the complaint is granted with respect to the deletion of certain class representatives and the addition of causes of action based on state law, and denied with respect to the addition of the words "or equivalents" in describing the victims alleged discrimination and retaliation. (Signed by Judge Gerard E. Lynch on 8/10/2004) (jp, ) (Entered: 08/11/2004)

DECLARATION of Bettina B. Plevan in Opposition re: 44 MOTION to Certify Class. Document filed by Willis Group Holdings Ltd., Willis North America Inc. (jco, ) (Entered: 08/23/2004)

DECLARATION of Paul F. White in Opposition re: 44 MOTION to Certify Class. (jco, ) (Entered: 08/23/2004)

AFFIDAVIT of Joan Gustafson Haworth, Ph.D. (jco, ) (Entered: 08/23/2004)

DECLARATION of Debora A. Dias` in Opposition re: 44 MOTION to Certify Class. Document filed by Willis Group Holdings Ltd., Willis North America Inc. (jco, ) (Entered: 08/23/2004)

MEMORANDUM OF LAW in Opposition re: 44 MOTION to Certify Class. Document filed by Willis Group Holdings Ltd., Willis North America Inc. (jco, ) (Entered: 08/23/2004)

AFFIDAVIT of Kristin S. Rozic in Opposition re: 44 MOTION to Certify Class. Document filed by Willis Group Holdings Ltd., Willis North America Inc. (jco, ) (Entered: 08/23/2004)

ENDORSED LETTER addressed to Judge Gerard E. Lynch from Jeremy M. Brown dated 8/16/04 re: defendant requests permission to file a memorandum of fifty (50) pages instead of twenty−five (25). Application GRANTED. Though in light of the fact that plaintiff's memorandum was only thirty−three (33) pages long, counsel are particularly reminded that concision enhances pursuasiveness. (Signed by Judge Gerard E. Lynch on 8/16/04) (db, ) (Entered: 08/24/2004)

SECOND AMENDED COMPLAINT amending 2 Amended Complaint against Willis of Massachusetts, Willis of New Jersey, Willis of NY, Willis Group Holdings Ltd., Willis North America Inc..Document filed by Shelley Hnot, Heidi Scheller. Related document: 2 Amended Complaint filed by Shelley Hnot, Maria Traverso, Teresa Jimenez, Margaret Mahon, Heidi Scheller.(djc, ) (Entered: 09/17/2004)

Set Answer Due Date re: 68 Amended Complaint, as to Willis Group Holdings Ltd. answer due on 9/27/2004; Willis North America Inc. answer due on 9/27/2004. (djc, ) (Entered: 09/17/2004)

ENDORSED LETTER addressed to Judge Gerard E. Lynch from Bettina B. Plevan dated 9/10/04. Granting the request for a briefing schedule as follows: Plaintiffs' opposition to summary judgment on behalf of Heidi Scheller to be filed on 9/30/04, with defendant's reply on 10/15/04. Plaintiffs' opposition to summary judgment on behalf of Shelley Hnot would be filed on 11/1/04, with defendant's reply on 11/22/04. Plaintiffs' reply in support of Class Certification would be filed on 9/20/04 as originally scheduled. (Signed by Judge Gerard E. Lynch on 9/16/04) (kw, ) (Entered: 09/23/2004)

ENDORSED LETTER addressed to Judge Gerard E. Lynch from Christine E. Webber dated 9/16/04. Granting plaintiffs' request for leave to submit a reply brief of no more than 40 page. (Signed by Judge Gerard E. Lynch on 9/16/04) (kw, ) (Entered: 09/23/2004)

REPLY MEMORANDUM OF LAW in Support re: 44 MOTION to Certify Class. Document filed by Shelley Hnot, Heidi Scheller. (kw, ) (Entered: 09/30/2004)

DECLARATION of Mark R. Killingsworth, D. Phil in Support re: 44 MOTION to Certify Class. Document filed by Shelley Hnot, Heidi Scheller. (kw, ) (Entered: 09/30/2004)

DECLARATION of Christine Webber in Support re: 44 MOTION to Certify Class. Document filed by Shelley Hnot, Heidi Scheller. (kw, ) (Entered: 09/30/2004)

ENDORSED LETTER addressed to Judge Gerard E. Lynch from Lawrence J. Profeta dated 9/29/04 re: granting Plaintiffs' leave to submit a memorandum of no more than 33 pages. Defendants are permitted leave to submit a reply memorandum of no more than fifteen pages. (Signed by Judge Gerard E. Lynch on 9/29/04) (sac, ) Modified on 10/14/2004 (sac, ). (Entered: 10/14/2004)

RULE 7.1 DISCLOSURE STATEMENT. Document filed by Willis of NY.(ps, ) (Entered: 10/19/2004)

RULE 7.1 DISCLOSURE STATEMENT. Document filed by Willis of New Jersey.(ps, ) (Entered: 10/19/2004)

RULE 7.1 DISCLOSURE STATEMENT. Document filed by Willis of Massachusetts.(ps, ) (Entered: 10/19/2004)

THIRD AMENDED ANSWER to SECOND Amended Complaint. Document filed by Willis Group Holdings Ltd., Willis North America Inc., Willis of Massachusetts, Willis of NY, Willis of New Jersey. Related document: 68 Amended Complaint, filed by Shelley Hnot, Heidi Scheller.(ps, ) (Entered: 10/19/2004)

DECLARATION of Shelley Hnot in Opposition re: 55 MOTION for Summary Judgment.. Document filed by Shelley Hnot. (jmi, ) (Entered: 11/08/2004)

ENDORSED LETTER addressed to Judge Lynch from Christine E. Webber dated 11/1/2004 re: plaintiff requesting leave to file a memorandum in opposition of 30 pages and Willis may submit a reply brief of up to 20 pages. Application granted. (Signed by Judge Gerard E. Lynch on 11/1/2004) (jsa, ) (Entered: 11/15/2004)

AMENDMENT TO STIPULATION AND AGREED PROTECTIVE ORDER; that in order to expedite the flow of electronic discovery and protect adequately for electronic discovery material produced by dfts that contains or may contain information protected by the atty−client privilege or atty work−product doctrine, the parties hereby amend the stipulation and agreed protective order dated 7/2/02 as set forth in this Order. (Signed by Judge Gerard E. Lynch on 11/3/04) (pl, ) (Entered: 11/22/2004)

ENDORSED LETTER addressed to Judge Gerard E. Lynch from Jeremy M. Brown dated 11/16/04 re: granting dfts requests for an extension until 12/6/04 to file their reply brief in support of their motion for summary judgment. (Signed by Judge Gerard E. Lynch on 11/16/04) (pl, ) (Entered: 11/30/2004)

OPINION AND ORDER # 91386. PLaintiffs have demonstrated that their proposed class and its representatives satisfy the requirements of Federal Rule of Civil Procedure 23(a) and 23(b). Accordingly, plaintiff's motion for class certification is granted. Hnot and Scheller are appointed as class representatives and Cohen, Milstein, Hausfeld and Toll,P.L.L.C. and Warshaw, Burstein, Schlesinger,&Kuh L.L.P. are appointed as co−lead counsel for the class. (Signed by Judge Gerard E. Lynch on 3/18/2005) (jsa, ) (Entered: 03/22/2005)

OPINION AND ORDER # 91474. Defendants' motion for summary judgment is granted with respect to plaintiff's constructive discharge claim, and with respect to any pay disparity claims accruing prior to September 11, 1998. Defendants' motion for summary judgment is denied with respect to plaintiff's pay disparity claims arising after that date. (Signed by Judge Gerard E. Lynch on 4/5/2005) (jsa, ) (Entered: 04/11/2005)

OPINION AND ORDER # 91475. Defendants' motion for summary judgment is denied with respect to all of plaintiff's timely claims of sex discrimination in violation of Title VII and state law, regarding compensation disparities, failure to promote, demotion and retaliation. Defendants' motion is granted as to all claims with respect to pay disparity and failure to promote claims that are time barred. (Signed by Judge Gerard E. Lynch on 4/5/2005) (jsa, ) Modified on 4/11/2005 (jsa, ). (Entered: 04/11/2005)

ORDER REFERRING CASE TO MAGISTRATE JUDGE. Order that case be referred to the Clerk of Court for assignment to a Magistrate Judge for settlement. Referred to Magistrate Judge Debra C. Freeman. (Signed by Judge Gerard E. Lynch on 5/11/05) (kw, ) (Entered: 05/27/2005)

Minute Entry for proceedings held before Judge Debra C. Freeman : Telephone Conference held on 6/13/2005. Next T/C set for 8/10/05 at 10:00 a.m. Tentative settlement date set for 8/17/05 at 11:00 a.m. (kw, ) (Entered: 06/22/2005)

Minute Entry for proceedings held before Judge Debra C. Freeman : Settlement Conference held on 8/15/2005. (djc, ) (Entered: 08/30/2005)

Minute Entry for proceedings held before Judge Debra C. Freeman : Settlement Conference held on 8/17/2005. (djc, ) (Entered: 08/30/2005)

ORDER of USCA (Certified Copy) USCA Case Number 05−8009−cv. Appellants move pursuant to Fed. R. Civ. P. 23(f) for an interlocutory appeal of the district court's order granting Appellees' motion for class certification. Upon due consideration, it is ORDERED that the Fed. R. Civ. P. 23(f) petition is denied because an immediate appeal is not warranted. See Sumitomo Copper Litigation V. Credit Lyonnais Rouse, Ltd., 262 F.3d 134, 139−40 (2d Cir. 2001). Roseann B. MacKechnie, Clerk USCA. Certified: 9/15/2005. (nd, ) (Entered: 09/19/2005)

ORDER: Plaintiff Scheller's request for clarification of the Court's opinion and order of 4/5/2005 is denied. (Signed by Judge Gerard E. Lynch on 8/10/2005) (lb, ) (Entered: 09/21/2005)

MANDATE of USCA (Certified Copy) USCA Case Number 05−8009−cv. Appellants move pursuant to Fed. R. Civ. P. 23(f) for an interlocutory appeal of the district court's order granting Appellees' motion for class certification. Upon due consideration, it is ORDERED that the Fed. R. Civ. P. 23(f) petition is denied because an immediate appeal is not warranted. See Sumitomo Copper Litigation V. Credit Lyonnais Rouse, Ltd., 262 F.3d 134, 139−40 (2d Cir. 2001). Roseann B. MacKechnie, Clerk USCA. Issued As Mandate: 10/6/2005. (nd, ) (Entered: 10/11/2005)

Transmission of USCA Mandate/Order to the District Judge re: 96 USCA Mandate Non−Dismissal,,. (nd, ) (Entered: 10/11/2005)

MOTION to Modify Class Certification Order. Document filed by Shelley Hnot, Maria Traverso, Teresa Jimenez, Margaret Mahon, Heidi Scheller. (jmi, ) (Entered: 11/17/2005)

DECLARATION of Christine E. Webber in Support re: 97 MOTION to Modify Class Certification Order.. Document filed by Shelley Hnot, Maria Traverso, Teresa Jimenez, Margaret Mahon, Heidi Scheller. (jmi, ) (Entered: 11/17/2005)

DECLARATION of Imelda Rama in Support re: 97 MOTION to Modify Class Certification Order.. Document filed by Shelley Hnot, Maria Traverso, Teresa Jimenez, Margaret Mahon, Heidi Scheller. (jmi, ) (Entered: 11/17/2005)

DECLARATION of Martin R. Lee in Support re: 97 MOTION to Modify Class Certification Order.. Document filed by Shelley Hnot, Maria Traverso, Teresa Jimenez, Margaret Mahon, Heidi Scheller. (jmi, ) (Entered: 11/17/2005)

STIPULATION AND ORDER: for plaintiffs and defendants tha Plaintiff Scheller's claim for constructive discharge pursuant to state law(s) and her compensation claim under Massachusetts law for period before September 11, 1998 is hereby dismissed pursuant to the Court's Opinion and Order dated April 5, 2005 from which Plaintiff Scheller retains her right to appeal.So Ordered. (Signed by Judge Gerard E. Lynch on 10/31/2005) (jmi, ) (Entered: 11/18/2005)

DECLARATION of Martin R. Lee in Support re: 97 MOTION to Modify Class Certification Order.. Document filed by Shelley Hnot, Heidi Scheller. (djc, ) (Entered: 11/23/2005)

OPPOSITION/RESPONSE to Motion re: 97 MOTION to Modify Class Certification Order.. Document filed by Willis Group Holdings Ltd., Willis North America Inc., Willis of Massachusetts, Willis of New Jersey, Willis of NY. (djc, ) (Entered: 12/05/2005)

DECLARATION of Jeremy M. Brown in Opposition re: 97 MOTION to Modify Class Certification Order.. Document filed by Willis Group Holdings Ltd., Willis North America Inc., Willis of Massachusetts, Willis of New Jersey, Willis of NY. (djc, ) (Entered: 12/05/2005)

DECLARATION of Paul F. White in Support of Opposititon to Plaintiffs'Motion to Modify Class Certification Order. Document filed by Willis Group Holdings Ltd., Willis North America Inc., Willis of Massachusetts, Willis of New Jersey, Willis of NY. (djc, ) (Entered: 12/05/2005)

ENDORSED LETTER addressed to Judge Gerard E.Lynch from Jeremy M. Brown dated 12/7/05 re: a request that the following schedule be approved: Motions due by 12/9/2005. Responses due by 12/21/2005. Replies due by 1/13/2006. ENDORSEMENT: SO ORDERED. (Signed by Judge Gerard E. Lynch on 12/7/05) (kco, ) (Entered: 12/12/2005)