Case: Krueger v. New York Telephone Co.

COMPLAINT filed; Summons issued and Notice pursuant to 28 U.S.C. 636(c); FILING FEE $ 120.00 RECEIPT # 183708 (sd) (Entered: 01/14/1993)

Case Information Statement Addendum and Case Designation to a Magistrate Judge filed. Purs. to statement, it is suggested that the case be classified as complex. Case is designated to Magistrate Judge Lee. (sd) (Entered: 01/14/1993)

STIPULATION and ORDER, reset answer due for 4/5/93 for NYNEX, for New York Telephone Co....So Ordered. ( signed by Judge Peter K. Leisure ). (sc) (Entered: 02/04/1993)

Pre-trial conference held by PKL (mk)

NOTICE OF MOTION by Evelyn Krueger, Francis J. Lupardo, Carylye D. Forde, Walter Grabowski, Nicholas T. Bruck, Albert J. Dwyer for an order directing defts to provide the names, addresses & other identifying information of all potential pltff class members, and authorizing notice to such individuals; permitting communication between pltffs' counsel & potential class zmembers with respect to the notice, Return date 4/5/93 (mk) (Entered: 03/16/1993)

MEMORANDUM by Evelyn Krueger, Francis J. Lupardo, Carylye D. Forde, Walter Grabowski, Nicholas T. Bruck, Albert J. Dwyer in support of [4-1] motion for an order directing defts to provide the names, addresses & other identifying information of all potential pltff class members, [4-2] motion authorizing notice to such individuals; permitting communication between pltffs' counsel & potential class zmembers with respect to the notice (mk) (Entered: 03/16/1993)

STIPULATION and ORDER, reset answer due for 4/19/93 for NYNEX, for New York Telephone C ( signed by Judge Peter K. Leisure ). (mk) (Entered: 03/31/1993)

STIPULATION and ORDER, Response to motion reset to 4/8/93 [4-1] motion for an order directing defts to provide the names, addresses & other identifying information of all potential pltff class members, reset to 4/8/93 [4-2] motion authorizing notice to such individuals; permitting communication between pltffs' counsel & potential class zmembers with respect to the notice, Reply to Response to Motion reset to 4/19/93 [4-1] motion for an order directing defts to provide the names, addresses & other identifying information of all potential pltff class members, reset to 4/19/93 [4-2] motion authorizing notice to such individuals; permitting communication between pltffs' counsel & potential class zmembers with respect to the notice, Return date reset to Return date reset to 4/19/93 [4-1] motion for an order directing defts to provide the names, addresses & other identifying information of all potential pltff class members, Return date reset to 4/19/93 [4-2] motion authorizing notice to such individuals; permitting communication between pltffs' counsel & potential class zmembers with respect to the notice ( signed by Judge Peter K. Leisure ). (cd) (Entered: 04/06/1993)

Filed Memo_Endorsement on letter by Mattew T. Miklave, dated 4/6/93, to Judge McKenna re: request an extension of time to file their Opposition and suggest the matter be addressed by the parties on April 9.... Granted. So Ordered: ( signed by Judge Lawrence M. McKenna ) (ys) (Entered: 04/14/1993)

Pre-trial conference held before Judge McKenna. (ys)

MEMORANDUM AND ORDER,... Plaintiffs are to file all motions regarding the collective nature of these actions or for class certification by April 16, 1993;, and The Court will hear oral argument and hold a conference on May 21, 1993 at 9:30 a.m., and Pending the conference to be held on May 21, 1993, all parties in both cases shall serve copies of all papers on all other parties in both cases., and Pending the conference to be held on May 21, 1993, ....This order does not constitute a consolidation of these cases. All issues regarding complete or partial consolidation are reserved. So Ordered: ( signed by Judge Lawrence M. McKenna ); Copies mailed (ys) (Entered: 04/16/1993)

Notice of reasgmnt _ to Judge Lawrence M. McKenna Copy of notice and judge's rules mailed to Attorney(s) of record: Judith P. Vladeck . (jl) (Entered: 04/15/1993)

STIPULATION and ORDER, reset answer due for 4/23/93 for NYNEX, for New York Telephone C. So Ordered: ( Signed by Judge McKenna). (ys) Modified on 04/21/1993 (Entered: 04/21/1993)

Filed Memo_Endorsement on letter by Judith P. Vladeck, dated 4/16/93, to Judge McKenna re: We believe that it was intended that paragraph one read: "Plaintiffs are to file all motions for notification of potential members of ADEA collective action by April 16, 1993...." So Ordered: ( signed by Judge Lawrence M. McKenna ) (ys) (Entered: 04/26/1993)

NOTICE by New York Telephone C, NYNEX to take deposition of Albert J. Dwyer on 6/15/93 at 10:00; subpoena(s) issued. (ys) (Entered: 04/29/1993)

NOTICE by New York Telephone C, NYNEX to take deposition of Walter Grabowski on 6/4/93 at 10:00; subpoena(s) issued. (ys) (Entered: 04/29/1993)

NOTICE by New York Telephone C, NYNEX to take deposition of Carlyle D. Forde on 6/9/93 at 10:00; subpoena(s) issued. (ys) (Entered: 04/29/1993)

NOTICE by New York Telephone C, NYNEX to take deposition of Francis J. Lupardo on 6/10/93 at 10:00; subpoena(s) issued. (ys) (Entered: 04/29/1993)

NOTICE by New York Telephone C, NYNEX to take deposition of Evelyn Krueger on 6/3/93 at 10:00; subpoena(s) issued. (ys) (Entered: 04/29/1993)

NOTICE by New York Telephone C, NYNEX to take deposition of Nicholas T. Bruck on 6/18/93 at 10:00; subpoena(s) issued. (ys) (Entered: 04/29/1993)

Pre-trial conference held before Judge McKenna on 4/28/93. (ys)

ANSWER to Complaint by New York Telephone C, NYNEX by attorney Susan Schenkel-Savitt for defendant NYNEX (ys) (Entered: 05/04/1993)

Rule 9 certificate filed by New York Telephone C, NYNEX. (see 93 cv 179). (ys) Modified on 05/06/1993 (Entered: 05/04/1993)

AFFIDAVIT of Lea P. Davies Re: in Support of Defendants' Memorandum of Law in Opposition to Plaintiffs; Motion to Notivy and Certify the Putative "ADEA Classes" in Krueger, et al. V. New York Telephone Co., 93 civ. 178(LMM) and Carroll, et al. v. New York Telephone Co., 93 civ. 179 (LMM). (ys) (Entered: 05/04/1993)

AFFIDAVIT of Judith Stoikov, Ph.D. (ys) (Entered: 05/06/1993)

MEMORANDUM by New York Telephone C, NYNEX in opposition to [4-1] motion for an order directing defts to provide the names, addresses & other identifying information of all potential pltff class members, [4-2] motion authorizing notice to such individuals; permitting communication between pltffs' counsel & potential class zmembers with respect to the notice (ys) (Entered: 05/06/1993)

Filed Memo_Endorsement on letter by Debra L. Raskin, dated 5/5/93, to Judge McKenna re: extending time...request that the Court advise us if our understanding is correct at the time that the Carroll plaintiffs' request is addressed. Time to file reply papers is Krueger and Carroll extended to 5/14/93. So Ordered: ( signed by Judge Lawrence M. McKenna ) (ys) (Entered: 05/07/1993)

REPLY MEMORANDUM by Evelyn Krueger, Francis J. Lupardo, Carylye D. Forde, Walter Grabowski, Nicholas T. Bruck, Albert J. Dwyer re: in Support of [4-1] motion for an order directing defts to provide the names, addresses & other identifying information of all potential pltff class members, [4-2] motion authorizing notice to such individuals; permitting communication between pltffs' counsel & potential class zmembers with respect to the notice (ys) (Entered: 05/19/1993)

AFFIDAVIT of Judith P. Vladeck Re: in Support of [4-1] motion for an order directing defts to provide the names, addresses & other identifying information of all potential pltff class members, [4-2] motion authorizing notice to such individuals; permitting communication between pltffs' counsel & potential class zmembers with respect to the notice (ys) (Entered: 05/19/1993)

CERTIFICATE OF SERVICE by Michael B. Ranis... that on May 14, 1993, I caused to be served by hand a copy of the plaintiffs' Reply Memorandum in Support of their motion to Notify the ADEA Class, and Affidavit of Judith P. Vladeck upon attorneys for defendants: Ronald Green, Esq., Epstein, Becker & Green P.C., 250 Park Avenue, New York, New York 10177 and Leonard N. Flamm, Esq., 880 Third Avenue, New York, New York 10017. (ys) (Entered: 05/19/1993)

Filed Memo_Endorsement on letter by Ronald M. Green, dated 5/18/93, to Judge McKenna re: reset oral argument set for 9:15 6/29/93. So Ordered: ( signed by Judge Lawrence M. McKenna ) (ys) (Entered: 05/24/1993)

Pre-trial conference held before Judge McKenna on 6/10/93. (ys)

NOTICE OF MOTION by New York Telephone C, NYNEX for Matthew T. Miklave to appear pro hac vice, Return date 7/13/93 (ys) (Entered: 06/29/1993)

Filed Memo_Endorsement on letter by Mary Beth Hynes, dated 6/24/93, to Judge McKenna re: that the Court permit me to be admitted pro hac vice.... Granted. So Ordered: ( signed by Judge Lawrence M. McKenna ) (ys) (Entered: 06/30/1993)

Memo endorsed on copy of motion; granting [29-1] motion for Matthew T. Miklave to appear pro hac vice. So Ordered: ( signed by Judge Lawrence M. McKenna ); Copies mailed. (ys) Modified on 07/02/1993 (Entered: 07/02/1993)

Pre-trial conference held (cd)

MEMORANDUM & ORDER granting [4-1] motion for an order directing defts to provide the names, addresses & other identifying information of all potential pltff class members, granting [4-2] motion authorizing notice to such individuals; permitting communication between pltffs' counsel & class zmembers with respect to the notice, the Carroll pltffs motion is granted in part & denied in part, Defts are ordered to release the names & addresses described above within 15 days of the Court's approval of a class definition, Deft's counsel wil draft a notice of the form & content described above, Pltffs counsel will submit a proposed ntc. with their respective comments to the Court within 7 days of receipt of te proposed notice drafted by defts ( signed by Judge Lawrence M. McKenna ); Copies mailed (mk) (Entered: 07/23/1993)

Transcript of record of proceedings filed for dates of 7/14/93 (rag) (Entered: 09/20/1993)

Filed Memo_Endorsement on letter dated 9/22/93, defts would be willing to submit the proposed response by close of business on 9/24/93 to plntfs comments regarding the proposed class notice ( signed by Judge Lawrence M. McKenna ) (cd) (Entered: 09/29/1993)

STIPULATION and ORDER, regarding confidential information during discovery ( signed by Judge Lawrence M. McKenna ). (cd) (Entered: 11/02/1993)

Filed Memo_Endorsement on letter dated 11/23/93, that the attached notice is approved ( signed by Judge Lawrence M. McKenna ) (cd) (Entered: 12/01/1993)

ORDER, consolidating cases; 93 cv 178 with 93cv179 and 93cv3606 ( signed by Judge Lawrence M. McKenna ); Copies mailed (cd) (Entered: 06/22/1994)

Consolidated Lead Case (cd)

NOTICE OF MOTION by Evelyn Krueger, Francis J. Lupardo, Carylye D. Forde, Walter Grabowski, Nicholas T. Bruck, Albert J. Dwyer to certify class action purs to FRCP 23 the claims purs to NY Human Rights Law, Exec. Law 290 et seq. & the Employee Retirement Income Sec. Act of 1974, 29 U.S.C. 1001 et seq., & declare that their ADEA claims may be maintained as a collective action purs to the Fair Labor Standards Act, 29 U.S.C. 216(b). With affidavits of Nicholas T. Bruck, Evelyn Krueger, Steven Hering, Henry Ritz, Francis J. Lupardo, Peter Donahue, Melody R. McGovern, Bernard F. Flanagan, Thomas J. Neville, Stephen Kaczmar, Patricia A. Walbroehl, Paula Behm, Janice Madden & Ronald G. Dunn. Return date 2/10/95 @2:00. (Also filed in #93cv179 LMM) (lam) Modified on 01/13/1995 (Entered: 01/13/1995)

MEMORANDUM by Evelyn Krueger, Francis J. Lupardo, Carylye D. Forde, Walter Grabowski, Nicholas T. Bruck, Albert J. Dwyer in SUPPORT of [38-1] motion to certify class action purs to FRCP 23 the claims purs to NY Human Rights Law, Exec. Law 290 et seq. & the Employee Retirement Income Sec. Act of 1974, 29 U.S.C. 1001 et seq., & declare that their ADEA claims may be maintained as a collective action purs to the Fair Labor Standards Act, 29 U.S.C. 216(b). (also filed in #93cv179 LMM) (lam) Modified on 01/13/1995 (Entered: 01/13/1995)

AFFIDAVIT in SUPPORT of Judith P. Vladeck, atty for by Evelyn Krueger, Francis J. Lupardo, Carylye D. Forde, Walter Grabowski, Nicholas T. Bruck, Albert J. Dwyer Re: [38-1] motion to certify class action purs to FRCP 23 the claims purs to NY Human Rights Law, Exec. Law 290 et seq. & the Employee Retirement Income Sec. Act of 1974, 29 U.S.C. 1001 et seq., & declare that their ADEA claims may be maintained as a collective action purs to the Fair Labor Standards Act, 29 U.S.C. 216(b). (also filed in #93cv0179 LMM) (lam) (Entered: 01/13/1995)

Notice of reasgmnt _ to Judge John G. Koeltl Copy of notice and judge's rules mailed to Attorney(s) of record: Matthew T. Miklave, Susan Schenkel-Savitt, Judith P. Vladeck . (dg) (Entered: 03/06/1995)

Filed Memo_Endorsement on letter dated 3/8/95, Response to motion [38-1] motion to certify class action purs to FRCP 23 the claims purs to NY Human Rights Law, Exec. Law 290 et seq. & the Employee Retirement Income Sec. Act of 1974, 29 U.S.C. 1001 et seq., & declare that their ADEA claims may be maintained as a collective action purs to the Fair Labor Standards Act, 29 U.S.C. 216(b). extended 30 days; and for 15 days in response in the Jackson and Hammil cases...the Court will review all pending motions at a conference to be scheduled... ( signed by Judge John G. Koeltl ) (cd) (Entered: 03/27/1995)

AFFIDAVIT of Judith P. Vladeck (pl) (Entered: 03/31/1995)

NOTICE by New York Telephone Company, NYNEX to take deposition upon oral examination of Janice Fanning Madden on 4/12/95, 3:00 p.m. at the offices of Epstein Becker & Green, P.C., 250 Park Avenue, 14th Floor, New York, NY 10177. (ae) (Entered: 04/04/1995)

AFFIDAVIT of Norman Mednick, atty for the Carroll pltffs in the consolidated actions Re: to inform the Court about additional individuals who have consented to join this action since 1/13/93, when opt-in Consent to Join forms were last submitted. (Also docketed in case #93cv0179 & #93cv3606). (lam) (Entered: 04/21/1995)

Filed Memo_Endorsement on letter dated 4/13/95, pretrial conference for 5:00 4/21/95 ( signed by Judge John G. Koeltl ) (cd) (Entered: 04/24/1995)

Pre-trial conference held (jr)

ORDER denying [38-1] motion to certify class action purs to FRCP 23 the claims purs to NY Human Rights Law, Exec. Law 290 et seq. & the Employee Retirement Income Sec. Act of 1974, 29 U.S.C. 1001 et seq., & declare that their ADEA claims may be maintained as a collective action purs to the Fair Labor Standards Act, 29 U.S.C. 216(b). ( signed by Judge John G. Koeltl ); Copies mailed (jr) (Entered: 05/09/1995)

Filed Memo-Endorsement on letter from Ronald M. Green to Judge Koeltl dated May 1, 1995, denying defendants' application to submit a responsive brief in excess of 35 pages, Response to motion for class certification reset to 5/5/95; reply to esponse to motion for class certification due 6/19/95 ( signed by Judge John G. Koeltl ) (jr) (Entered: 05/09/1995)

ORDER, set discovery due for 11/1/95, and set pretrial order due for 12/8/95, and set pretrial conference for 12/22/95 ( signed by Judge John G. Koeltl ); Copies mailed (jr) (Entered: 05/09/1995)

Filed Memo-Endorsement on letter to Judge Koeltl from Ronald M. Green dated 5/2/95, In Re: writing to request that the Court reconsider its denial of our application to submit a responsive brief in excess of 35 pages.....Application for rearguement denied. No new matters are presented. See Rule 3(j) of the SDNY Civil Rules. Deft had no right simply to ignore the limits or pages in briefs. Moreover, there is no excuse for not having made a timely request in the first instance, or for having failed to ever checked how the Court deposed of this application. The Court has provided additional time to submit a brief with its proper page lengths. ( signed by Judge John G. Koeltl ) (kg) (Entered: 05/09/1995)

Order that the case be referred to the Clerk of Court for assignment to a Magistrate Judge for settlement ( signed by Judge John G. Koeltl ) Referred to Magistrate Judge Barbara A. Lee applies to 93cv 179; 93cv3606; 94cv3272; 94cv2208, as well (cd) (Entered: 05/09/1995)

Documents redacted pursuant to prividege or on grounds of non-responsiveness. (ae) (Entered: 05/25/1995)

Documents withheld pursuant to a claim of privilege. (ae) (Entered: 05/25/1995)

AFFIDAVIT in opposition of Ronald M. Green by New York Telephone C, NYNEX Re: [38-1] motion to certify class action purs to FRCP 23 the claims purs to NY Human Rights Law, Exec. Law 290 et seq. & the Employee Retirement Income Sec. Act of 1974, 29 U.S.C. 1001 et seq., & declare that their ADEA claims may be maintained as a collective action purs to the Fair Labor Standards Act, 29 U.S.C. 216(b). (ls) (Entered: 05/25/1995)

MEMORANDUM by New York Telephone C, NYNEX in opposition to [38-1] motion to certify class action purs to FRCP 23 the claims purs to NY Human Rights Law, Exec. Law 290 et seq. & the Employee Retirement Income Sec. Act of 1974, 29 U.S.C. 1001 et seq., & declare that their ADEA claims may be maintained as a collective action purs to the Fair Labor Standards Act, 29 U.S.C. 216(b). (ls) (Entered: 05/25/1995)

AFFIDAVIT in support of Judith Stoikov by New York Telephone C, NYNEX Re: [55-1] opposition memorandum (ls) (Entered: 05/25/1995)

SUPPLEMENTAL MEMORANDUM by New York Telephone C, NYNEX in opposition to [38-1] motion to certify class action purs to FRCP 23 the claims purs to NY Human Rights Law, Exec. Law 290 et seq. & the Employee Retirement Income Sec. Act of 1974, 29 U.S.C. 1001 et seq., & declare that their ADEA claims may be maintained as a collective action purs to the Fair Labor Standards Act, 29 U.S.C. 216(b). (ls) Modified on 05/25/1995 (Entered: 05/25/1995)

Filed Memo_Endorsement on letter by Amy J. Beech to Magistrate Judge Lee dated 5/25/95, Atty Beech is directed to notify all other counsel by fax machine. July 5 is not an available date. Counsel are directed to see up a telephone conference with the undersigned for Tuesday, 5/30/95 or Wednesday, 5/31/95 by telephoning my Courtroom depty Helen Lewis at 637-0108. SO ORDERED: ( signed by Magistrate Judge Barbara A. Lee ) (ae) (Entered: 05/31/1995)

NOTICE OF MOTION by Evelyn Krueger, Francis J. Lupardo, Carylye D. Forde, Walter Grabowski, Nicholas T. Bruck, Albert J. Dwyer to proceed as a collective action, Return date 6/21/95 (ae) (Entered: 06/06/1995)

Filed Memo_Endorsement on letter by Ronald M. Green to Magistrate Judge Koeltl dated 6/2/95, Reset settlement conference for 10:00 6/26/95. Pre-conference submissions are due no later than 4 p.m. 6/22/95. SO ORDERED: ( signed by Magistrate Judge Barbara A. Lee ) (ae) (Entered: 06/06/1995)

ORDER, the cases have already been referred to MJ Lee for settlement discussions and no reference will be made for the resolution of discovery disputes ( signed by Judge John G. Koeltl ); Copies mailed (cd) (Entered: 06/07/1995)

Order of dismissal of Jay C. Johnson with prejudice from the above-captioned lawsuit. SO ORDERED: ( signed by Judge John G. Koeltl ) (ae) (Entered: 06/19/1995)

REPLY MEMORANDUM by Evelyn Krueger, Francis J. Lupardo, Carylye D. Forde, Walter Grabowski, Nicholas T. Bruck, Albert J. Dwyer IN SUPPORT OF pltffs' motion for class certification (ls) (Entered: 06/22/1995)

AFFIDAVIT in support of Julian R. Birnbaum by Evelyn Krueger, Francis J. Lupardo, Carylye D. Forde, Walter Grabowski, Nicholas T. Bruck, Albert J. Dwyer Re: [63-1] reply memorandum (ls) (Entered: 06/22/1995)

AFFIDAVIT of Mia M. Meloni by Evelyn Krueger, Francis J. Lupardo, Carylye D. Forde, Walter Grabowski, Nicholas T. Bruck, Albert J. Dwyer Re: Affvt. of Frank J. Landy, Ph.D sworn to 5/1/95, and documents which were produced by defts. (ls) (Entered: 06/22/1995)

AFFIDAVIT of Janice Fanning Madden by Evelyn Krueger, Francis J. Lupardo, Carylye D. Forde, Walter Grabowski, Nicholas T. Bruck, Albert J. Dwyer Re: Affdvt. of Judith Stoikov, sworn to 5/19/95 and submitted by defts in this action (ls) (Entered: 06/22/1995)

AFFIDAVIT of Janice Fanning Madden by Evelyn Krueger, Francis J. Lupardo, Carylye D. Forde, Walter Grabowski, Nicholas T. Bruck, Albert J. Dwyer (ls) (Entered: 06/22/1995)

Settlement conference held before Magistrate Judge Lee. (rag)

REPLY MEMORANDUM by The Carroll Pltff's IN FURTHER SUPPORT of their motion to procees as a collective action (ls) (Entered: 07/05/1995)

AFFIDAVIT of Walter Grabowski Re:... his understanding that he as well as the other class representatives, are responsible for the costs associated with this ligigation - and have conributed $500 towards the costs of the litigation. (djc) (Entered: 06/30/1995)

AFFIDAVIT of Evelyn Krueger Re: ...her understanting that she, as well as the other class representatives, are responsible for the costs associated with this litigation. She has contributed $500 towards the costs of the litigation. (lam) (Entered: 07/10/1995)

AFFIDAVIT of Janice Fanning Madden Re: [56-1] affidavit (ls) (Entered: 07/11/1995)

AFFIDAVIT of Janice Fanning Madden by Evelyn Krueger, Francis J. Lupardo, Carylye D. Forde, Walter Grabowski, Nicholas T. Bruck, Albert J. Dwyer Re: (djc) (Entered: 08/31/1995)

NOTICE OF MOTION by Evelyn Krueger, Francis J. Lupardo, Carylye D. Forde, Walter Grabowski, Nicholas T. Bruck, Albert J. Dwyer for protective order, and for Bifurcation (djc) (Entered: 08/31/1995)

AFFIDAVIT in support of julian R. Birnbaum by Evelyn Krueger, Francis J. Lupardo, Carylye D. Forde, Walter Grabowski, Nicholas T. Bruck, Albert J. Dwyer Re: [73-1] motion for protective order, [73-2] motion and for Bifurcation (djc) (Entered: 08/31/1995)

MEMORANDUM by Evelyn Krueger, Francis J. Lupardo, Carylye D. Forde, Walter Grabowski, Nicholas T. Bruck, Albert J. Dwyer in OPPOSITION to defts' Motion to Compel Discovery. (lam) (Entered: 08/31/1995)

AFFIDAVIT of Janice Fanning Madden, economist (who ananalyzes compensation patterns) by Evelyn Krueger, Francis J. Lupardo, Carylye D. Forde, Walter Grabowski, Nicholas T. Bruck, Albert J. Dwyer Re: NYNEX Compensation. (lam) (Entered: 08/31/1995)

MEMORANDUM OF LAW by New York Telephone C, NYNEX in support of Motion to Compel Discovery. (djc) (Entered: 09/01/1995)

REPLY MEMORANDUM by New York Telephone C, NYNEX re: [73-1] motion for protective order, [73-2] motion and for Bifurcation (ls) (Entered: 09/06/1995)

Case Management Plan in a Standard or Complex Case: 1. Parties shall file simultaneous briefs in the form of cross motions to compel or applications for protective orders with respect to outstanding discovery requested form members of the purported class and consent signers. 2. Such briefs shall be served by 8/23/95, with simultaneous replies served by 8/25/95. SO ORDERED: ( signed by Judge John G. Koeltl ) (ae) (Entered: 09/07/1995)

MEMORANDUM OPINION # 75505 denying [73-2] motion and for Bifurcation granting [73-1] motion for protective order; see document ( Signed by Judge John G. Koeltl ); Copies mailed. (cd) (Entered: 10/03/1995)

MEMORANDUM OPINION # 75504, the Krueger plntfs seek to certify a class action withe respect to both the state HRL and ERISA claims, and authorize a collective action with respect to their ADEA claims... ( Signed by Judge John G. Koeltl ); Copies mailed. (cd) (Entered: 10/03/1995)

ORDER REFERRING CASE to Dean John Feerick of Fordham Law School as a special master in these matters for the purposes of assisting the parties in settlement discussions. The master's compensation shall be paid by the parties equally. SO ORDERED: ( signed by Judge John G. Koeltl ) (ae) (Entered: 12/26/1995)

ORDER, discovery due for 1/19/96, motion filing deadline for 2/9/96, pretrial order due for 3/1/96, trial ready deadline 3/8/96; See document for other deadlines ( signed by Judge John G. Koeltl ); Copies mailed (cd) (Entered: 12/26/1995)

Filed Memo_Endorsement on letter dated 12/15/95, Dr. Stoikov's supplemental report is to be served by 1/5/96, plntf may take Dr. Stoikov's deposition after she returns and before 1/30/96 ( signed by Judge John G. Koeltl ) (cd) (Entered: 12/29/1995)

ORDER, Ana Maria Cerrudo is dismissed with prejudice from the above-captioned lawsuit. ( signed by Judge John G. Koeltl ); Copies mailed (kg) (Entered: 01/19/1996)

Case reopened (closed in error) (kg)

Case closed (kg)

Filed Memo_Endorsement on letter by Amy J. Becch to Judge Koeltl dated 1/25/96, The requirement to produce all documents intended to be used as trial exhibits by 3/8/96 does not extend to charts and other graphic material for illustrative purposes which are prepared for litigation. The parties should agree on a procedure and timetable for litigation and review to permit mutual verification. SO ORDERED: ( signed by Judge John G. Koeltl ) (ae) (Entered: 02/05/1996)

Filed Memo_Endorsement on letter dated 1/22/96, pretrial order due for 1/23/96 ( signed by Judge John G. Koeltl ) (cd) (Entered: 02/05/1996)

ORDER, set discovery, including experts due for 3/8/96 ; The deadline for serving & filing dispositive motions is 3/29/96 ; Defts will immediately produce all material used....by their experts to the extent not previously provided ; Pltffs will produce all "damage questionnaires" by 1/19/96 ; By 1/26/96 defts will provide pltffs' counsel with a list of those to be deposed by phone to be conducted bet. 1/29/96 & 2/16/96 ; Pltffs to serve any rebuttal reports to Dr. Perl or Dr. Landy's reports on or before 2/9/96 & depositions of rebuttal experts by 2/23/96 ; Parties to designate any compensatory damages expert by 2/2/96 and serve any report from that expert by 2/9/96, Depositions of experts by 2/16/96 ; Parties to designate any rebuttal compensatory damages expert by 2/16/96, to serve rebuttal report from expert by 3/1/96 and experts to be available for deposition on or before 3/8/96 ; Parties will produce all documents intended for use as trial exhibits by 3/8/96 ; The pltffs reserved the right to make any applications in connection with these examinations. ( signed by Judge John G. Koeltl ) Copies mailed (lam) (Entered: 02/09/1996)

Filed Memo_Endorsement on letter dated 2/7/96, Response to motion to dismiss by 2/16/96 for plntfs ( signed by Judge John G. Koeltl ) (cd) (Entered: 02/14/1996)

ORDER, dismissing John W. Erdmann with prejudice from the above-captioned lawsuit. ( signed by Judge John G. Koeltl ); Copies mailed (kg) (Entered: 02/21/1996)