Case: Hnot v. Willis Group Holdings

1:01-cv-06558 | U.S. District Court for the Southern District of New York

Filed Date: July 19, 2001

Closed Date: 2011

Clearinghouse coding complete

Case Summary

On July 19, 2001, female employees of an insurance brokerage firm filed this class action in the U.S. District Court for the Southern District of New York. The plaintiffs sued Willis Group Holdings (Willis) and its American affiliates and subsidiaries under Title VII of the Civil Rights Act of 1964 for claims of sex discrimination. The plaintiffs, represented by two private firms, sought damages, injunctive relief, and attorneys’ fees and costs. They claimed that the defendants had a pattern an…

On July 19, 2001, female employees of an insurance brokerage firm filed this class action in the U.S. District Court for the Southern District of New York. The plaintiffs sued Willis Group Holdings (Willis) and its American affiliates and subsidiaries under Title VII of the Civil Rights Act of 1964 for claims of sex discrimination. The plaintiffs, represented by two private firms, sought damages, injunctive relief, and attorneys’ fees and costs. They claimed that the defendants had a pattern and practice of discriminating against female employees—in compensation, assignment of projects and promotions, various terms and conditions of employment—and that an employee retaliated against one woman who complained about Willis’ discrimination. The case was assigned to Judge Gerard E. Lynch.

Two of the original named plaintiffs accepted offers of judgment from the defendant for $75,000 each on December 8, 2003. But the two remaining named plaintiffs continued to pursue their claims. The defendant filed separate motions for summary judgment against each named plaintiff on July 15 and August 23, 2004.

Meanwhile, the plaintiffs filed a second amended complaint on September 17, 2004, claiming that the defendant also violated New York, Massachusetts, and New Jersey anti-discrimination laws. On March 21, 2005, the court certified a class consisting of "all current and former female employees who have been employed by the defendants in positions eligible for the award of officer titles” between 1998 and 2001.

On April 8, 2005, the court granted summary judgment for the defendant on the named-plaintiff’s pay disparity claims because they fell outside the statute of limitations. However, the court allowed claims that were not excluded by the statute of limitations to proceed. The court also granted summary judgment for the defendants on the plaintiff's constructive discharge claim because she had not shown any evidence that her co-worker’s actions were motivated by her gender. And three days later, the court issued an opinion granting summary judgment for the defendants on the second named plaintiff’s claims because those were also outside the statute of limitations. However, the court allowed her to proceed on all of her pay disparity claims, as well as her claims about demotion, failure to promote, and retaliation.

The defendant filed a third motion for summary judgment on December 9, 2005, and a motion for sanctions, charging the plaintiff with bringing frivolous charges under New York law. The court dismissed the plaintiffs’ state claims on July 25, 2006 but denied the motion for sanctions. The court concluded that the plaintiff’s New York claims could not stand because her superiors in Massachusetts had set the salary rates, not her superiors in New York. However, the plaintiff’s claims under New Jersey and Massachusetts state law survived. The Second Circuit affirmed this order in Hnot v. Willis Group Holdings, Ltd., 234 Fed. Appx. 13 (2d Cir. 2007).

The suit proceeded on track for trial for the next year, but the parties settled in 2007. On October 18, 2007, the plaintiffs submitted a motion for preliminary approval of a consent decree, and on October 22, the court granted preliminary approval. The court granted final approval on February 25, 2008, retaining jurisdiction over the decree. The court awarded a consent judgment for the plaintiffs’ representation providing one firm more than $2.5 million and the other more than $1.7 million in attorneys’ fees and expenses. The consent decree was set to last for three years. The settlement fund to the plaintiff class was $8.5 million. The consent decree said that an expert witness would be used to determine the total lost wages of each individual class member. And the settlement provided no rights to opt out and indefinitely released the defendant from future liability.

The consent decree also specified injunctive relief that would be subject to outside monitoring. The defendants agreed to develop new objective systems for performance evaluation and compensation of employees and would submit those to the monitor. They also agreed to provide data on compensation and promotion practices to the monitor and to comply with the state and federal statutes cited in the complaint. The parties appointed the monitor at the defendant’s expense.

The court retained jurisdiction through the duration of the consent decree, which expired in 2011. The case is now closed.

Summary Authors

Eric Weiler (7/1/2010)

Nathan Santoscoy (3/17/2019)

People

For PACER's information on parties and their attrorneys, see: https://www.courtlistener.com/docket/4957925/parties/hnot-v-willis-group/


Judge(s)

Freeman, Debra Carol (New York)

Lynch, Gerard E. (New York)

Sack, Robert David (New York)

Attorneys(s) for Plaintiff

Coleman, Llezlie Green (District of Columbia)

Glick, Jessica M. (District of Columbia)

Green, Llezlie Lloren (New York)

Hall, Peter W. (Vermont)

Lee, Martin R. (New York)

Less, Martin R. (New York)

Lew, Avi (New York)

Judge(s)

Freeman, Debra Carol (New York)

Lynch, Gerard E. (New York)

Sack, Robert David (New York)

Attorneys(s) for Plaintiff

Coleman, Llezlie Green (District of Columbia)

Glick, Jessica M. (District of Columbia)

Green, Llezlie Lloren (New York)

Hall, Peter W. (Vermont)

Lee, Martin R. (New York)

Less, Martin R. (New York)

Lew, Avi (New York)

Lyn, Jessica Glick (New York)

Nussbaum, Linda P. (New York)

Profeta, Lawrence J. (New York)

Reid, Keri L. (New York)

Sellers, Joseph Marc (District of Columbia)

Sotomayor, Sonia (District of Columbia)

Webber, Christine E. (District of Columbia)

Yakren, Sofia (New York)

Attorneys(s) for Defendant

Brown, Jeffrey M. (Florida)

Plevan, Bettina Barasch (New York)

Rozic, Kristin S. (New York)

Rumeld, Myron D. (New York)

Other Attorney(s)

Fink, Rosalind (New York)

Freedman, Spencer B. (New York)

Herbst, Robert L. (New York)

Documents in the Clearinghouse

Document

1:01-cv-06558

Docket [PACER]

June 12, 2012

June 12, 2012

Docket
57

1:01-cv-06558

Opinion [Granting In Part And Denying In Part Plaintiffs' Motion To File Second Amended Complaint]

2004 WL 1794493, 2004 U.S.Dist.LEXIS 15734

Aug. 10, 2004

Aug. 10, 2004

Order/Opinion
68

1:01-cv-06558

Second Amended Complaint

Sept. 17, 2004

Sept. 17, 2004

Complaint
90

1:01-cv-06558

Opinion And Order [Granting Class Certification]

228 F.R.D. 476

March 21, 2005

March 21, 2005

Order/Opinion
92

1:01-cv-06558

Opinion And Order [Granting In Part And Denying In Part Defendant's Motion For Summary Judgment]

2005 WL 831665, 2005 U.S.Dist.LEXIS 6064

April 8, 2005

April 8, 2005

Order/Opinion
92

1:01-cv-06558

Opinion And Order [Granting In Part And Denying In Part Defendant's Motion For Summary Judgment]

2005 WL 831664, 2005 U.S.Dist.LEXIS 6066

April 8, 2005

April 8, 2005

Order/Opinion
121

1:01-cv-06558

Opinion And Order [Granting Defendants' Motion For Summary Judgment; Dismissing Plaintiff's Pay Disparity Claim Under The New York Human Rights Law; And Denying Defendants' Motion For Sanctions]

2006 WL 2079326, 2006 U.S.Dist.LEXIS 52082

July 25, 2006

July 25, 2006

Order/Opinion
124

1:01-cv-06558

Opinion And Order [Denying Plaintiffs' Motions To Amend The RCMP, Compel Further Discovery And Modify The Class Certification Order]

2006 WL 2381869, 2006 U.S.Dist.LEXIS 52612

Aug. 17, 2006

Aug. 17, 2006

Order/Opinion
134

1:01-cv-06558

Opinion And Order [Denying Plaintiff-Intervenor Adrianne Cronas's Motion To Intervene And Be Appointed Class Representative]

2006 WL 3476746, 2006 U.S.Dist.LEXIS 87091

Nov. 30, 2006

Nov. 30, 2006

Order/Opinion

06-05761

Appellant's [Plaintiff-Intervenor] Brief

U. S. Court of Appeals for the Second Circuit

Feb. 15, 2007

Feb. 15, 2007

Pleading / Motion / Brief

Resources

Docket

See docket on RECAP: https://www.courtlistener.com/docket/4957925/hnot-v-willis-group/

Last updated Aug. 2, 2022, 3:01 a.m.

ECF Number Description Date Link Date / Link
1

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

July 19, 2001

July 19, 2001

121

OPINION AND ORDER #93411 re: 111 MOTION for Sanctions, is denied. filed by Willis Group Holdings Ltd.,, Willis North America Inc.,, Willis of NY,, Willis of New Jersey,, Willis of Massachusetts,, 107 MOTION for Summary Judgment. filed by Willis Group Holdings Ltd.,, Willis North America Inc.,, Willis of NY,, Willis of New Jersey,, Willis of Massachusetts, is granted, plaintiff's pay dispaity claim under the New York Human Right Law is Dismissed. (Signed by Judge Gerard E. Lynch on 7/24/2006) (jmi, ) Modified on 7/28/2006 (lb, ).

July 25, 2006

July 25, 2006

RECAP
124

OPINION AND ORDER # 93556 re: 97 MOTION to Modify Class Certification Order filed by Shelley Hnot,, Maria Traverso,, Teresa Jimenez,, Margaret Mahon,, Heidi Scheller. Since plaintiffs have failed to establish a sufficient basis to amend the RCMP, to compel further discovery, or to modify the class certification order, their motion (doc #97) is DENIED. (Signed by Judge Gerard E. Lynch on 8/17/2006) (lb, ) Modified on 8/18/2006 (rw, ).

Aug. 17, 2006

Aug. 17, 2006

RECAP
2

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)

Oct. 2, 2001

Oct. 2, 2001

134

OPINION AND ORDER # 93992 re: 122 MOTION to Intervene filed by Adrianne Cronas. Having considered the totality of the circumstances, the Court denies as untimely Cronas's motion to intervene pursuant to F.R.C.P. 24(a) and (b). The Court ther efore also denies Cronas's request to be appointed a class representative, her request to appoint her attorney as co-class counsel, and her requests to expand the class period and re-open discovery. As Cronas is not yet a party to this or any re lated action, her request to be considered a "party" for purposes of the confidentiality stipulation and order in the Hnot litigation is also denied, without prejudice to renewal at a later date. So Ordered. (Signed by Judge Gerard E. Lynch on 11/30/06) (jco, ) Modified on 12/12/2006 (jco, ). Modified on 3/14/2007 (rw).

Nov. 30, 2006

Nov. 30, 2006

RECAP
2

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

Oct. 2, 2001

Oct. 2, 2001

176

OPINION AND ORDER #94744: Defendants argue that Borgida's testimony is not sufficiently tried to the facts of this case, or in the alternative, that his testimony is unfairly prejudicial. Defendants motion will be DENIED. Finally the Court is co nstrained to note the disappointingly tendentious quality of defendants briefing of these issues. Defendants correctly note that some Court's have excluded Borgida's testimony. Defendant's motion to exclude the testimony of Eugene Borgida is DENIED. (Signed by Judge Gerard E. Lynch on 6/1/07) (js)

June 1, 2007

June 1, 2007

RECAP
3

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)

Oct. 17, 2001

Oct. 17, 2001

5

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)

Dec. 26, 2001

Dec. 26, 2001

4

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)

Dec. 27, 2001

Dec. 27, 2001

6

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)

Jan. 8, 2002

Jan. 8, 2002

7

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

Jan. 9, 2002

Jan. 9, 2002

8

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)

Jan. 9, 2002

Jan. 9, 2002

9

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)

Jan. 9, 2002

Jan. 9, 2002

10

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)

Jan. 10, 2002

Jan. 10, 2002

11

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

Jan. 29, 2002

Jan. 29, 2002

12

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)

Jan. 30, 2002

Jan. 30, 2002

13

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)

Feb. 1, 2002

Feb. 1, 2002

14

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)

July 2, 2002

July 2, 2002

15

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)

Aug. 2, 2002

Aug. 2, 2002

16

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)

Aug. 7, 2002

Aug. 7, 2002

17

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)

Sept. 9, 2002

Sept. 9, 2002

18

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)

Nov. 19, 2002

Nov. 19, 2002

19

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)

Nov. 27, 2002

Nov. 27, 2002

20

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)

Dec. 2, 2002

Dec. 2, 2002

21

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

Dec. 31, 2002

Dec. 31, 2002

22

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)

Oct. 22, 2003

Oct. 22, 2003

23

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)

Oct. 24, 2003

Oct. 24, 2003

24

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)

Nov. 5, 2003

Nov. 5, 2003

25

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

Nov. 20, 2003

Nov. 20, 2003

26

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

Nov. 20, 2003

Nov. 20, 2003

27

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

Nov. 20, 2003

Nov. 20, 2003

28

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)

Nov. 24, 2003

Nov. 24, 2003

29

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

Dec. 8, 2003

Dec. 8, 2003

30

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

Dec. 8, 2003

Dec. 8, 2003

31

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

Dec. 8, 2003

Dec. 8, 2003

34

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)

Dec. 31, 2003

Dec. 31, 2003

33

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)

Jan. 7, 2004

Jan. 7, 2004

35

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)

Jan. 13, 2004

Jan. 13, 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)

Jan. 13, 2004

Jan. 13, 2004

36

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)

March 16, 2004

March 16, 2004

37

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)

March 16, 2004

March 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)

March 17, 2004

March 17, 2004

38

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

March 19, 2004

March 19, 2004

39

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)

March 30, 2004

March 30, 2004

40

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)

May 11, 2004

May 11, 2004

41

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)

May 20, 2004

May 20, 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)

May 20, 2004

May 20, 2004

42

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)

June 4, 2004

June 4, 2004

43

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)

June 4, 2004

June 4, 2004

44

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)

June 14, 2004

June 14, 2004

45

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)

June 14, 2004

June 14, 2004

47

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)

June 16, 2004

June 16, 2004

48

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)

June 21, 2004

June 21, 2004

49

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)

June 29, 2004

June 29, 2004

50

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)

June 29, 2004

June 29, 2004

51

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)

July 7, 2004

July 7, 2004

52

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

July 7, 2004

July 7, 2004

55

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)

July 15, 2004

July 15, 2004

57

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)

Aug. 10, 2004

Aug. 10, 2004

58

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)

Aug. 20, 2004

Aug. 20, 2004

59

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

Aug. 20, 2004

Aug. 20, 2004

60

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

Aug. 20, 2004

Aug. 20, 2004

61

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)

Aug. 20, 2004

Aug. 20, 2004

62

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)

Aug. 20, 2004

Aug. 20, 2004

63

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)

Aug. 20, 2004

Aug. 20, 2004

66

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)

Aug. 23, 2004

Aug. 23, 2004

68

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)

Sept. 17, 2004

Sept. 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)

Sept. 17, 2004

Sept. 17, 2004

69

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)

Sept. 20, 2004

Sept. 20, 2004

70

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)

Sept. 20, 2004

Sept. 20, 2004

71

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

Sept. 29, 2004

Sept. 29, 2004

72

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)

Sept. 29, 2004

Sept. 29, 2004

73

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

Sept. 29, 2004

Sept. 29, 2004

76

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)

Oct. 12, 2004

Oct. 12, 2004

78

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

Oct. 15, 2004

Oct. 15, 2004

79

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

Oct. 15, 2004

Oct. 15, 2004

80

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

Oct. 15, 2004

Oct. 15, 2004

81

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)

Oct. 15, 2004

Oct. 15, 2004

85

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

Nov. 1, 2004

Nov. 1, 2004

86

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)

Nov. 12, 2004

Nov. 12, 2004

87

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)

Nov. 12, 2004

Nov. 12, 2004

88

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)

Nov. 18, 2004

Nov. 18, 2004

90

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)

March 21, 2005

March 21, 2005

92

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)

April 8, 2005

April 8, 2005

91

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)

April 11, 2005

April 11, 2005

93

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)

May 25, 2005

May 25, 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)

June 13, 2005

June 13, 2005

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

Aug. 15, 2005

Aug. 15, 2005

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

Aug. 17, 2005

Aug. 17, 2005

94

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)

Sept. 16, 2005

Sept. 16, 2005

95

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)

Sept. 19, 2005

Sept. 19, 2005

96

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)

Oct. 7, 2005

Oct. 7, 2005

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

Oct. 11, 2005

Oct. 11, 2005

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)

Nov. 16, 2005

Nov. 16, 2005

98

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)

Nov. 16, 2005

Nov. 16, 2005

99

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)

Nov. 16, 2005

Nov. 16, 2005

100

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)

Nov. 16, 2005

Nov. 16, 2005

101

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)

Nov. 18, 2005

Nov. 18, 2005

102

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)

Nov. 22, 2005

Nov. 22, 2005

Case Details

State / Territory: New York

Case Type(s):

Equal Employment

Special Collection(s):

IWPR/Wage Project Consent Decree Study

Private Employment Class Actions

Key Dates

Filing Date: July 19, 2001

Closing Date: 2011

Case Ongoing: No

Plaintiffs

Plaintiff Description:

All current and former female employees who have been employed by the defendants in positions eligible for the award of officer titles” between 1998 and 2001

Plaintiff Type(s):

Private Plaintiff

Public Interest Lawyer: No

Filed Pro Se: No

Class Action Sought: Yes

Class Action Outcome: Granted

Defendants

Willis Group Holdings, Ltd., Private Entity/Person

Willis Group Holdings, Ltd. (London, England, U.K.), Private Entity/Person

Case Details

Causes of Action:

State law

Title VII (including PDA), 42 U.S.C. § 2000e

State Anti-Discrimination Law

Availably Documents:

Trial Court Docket

Monetary Relief

Injunctive (or Injunctive-like) Relief

Any published opinion

Outcome

Prevailing Party: Plaintiff

Nature of Relief:

Injunction / Injunctive-like Settlement

Damages

Source of Relief:

Settlement

Form of Settlement:

Court Approved Settlement or Consent Decree

Amount Defendant Pays: 12,750,000

Order Duration: 2008 - 2011

Content of Injunction:

Discrimination Prohibition

Follow recruitment, hiring, or promotion protocols

Monitor/Master

Monitoring

Other requirements regarding hiring, promotion, retention

Recordkeeping

Reporting

Retaliation Prohibition

Utilize objective hiring/promotion criteria

Issues

General:

Disparate Treatment

Pattern or Practice

Retaliation

Discrimination-area:

Demotion

Other Conditions of Employment (including assignment, transfer, hours, working conditions, etc)

Pay / Benefits

Promotion

Seniority

Discrimination-basis:

Sex discrimination

Affected Gender:

Female