Arnold v. Cargill Inc.

Arnold v. Cargill Inc.

Arnold v. Cargill Inc.

Arnold v. Cargill Inc.

Arnold v. Cargill Inc.

Arnold v. Cargill Inc.

Arnold v. Cargill Inc.

CLASS ACTION COMPLAINT - INJUNCTIVE RELIEF SOUGHT. JURY TRIAL DEMANDED. Summons issued. Assigned to Judge Ann D. Montgomery per individual civil rights list list and referred to Magistrate Judge Arthur J. Boylan. Receipt # 253552 for $150.00 (39 pgs) (MKC)

ORDER OF RECUSAL( Judge Ann D. Montgomery / 11/19/01) Case reassigned to Judge Donovan W. Frank per the Individual civil rights list. (2 pgs) (cc: all counsel) (MKC)

SUMMONS - RETURN OF SERVICE executed upon defendant Cargill Incorporated on 11/15/01 . (2 pgs) (MKC)

PETITION AND ORDER for admission pro hac vice (Clerk, Richard D. Sletten ) on behalf of pltfs by M. Lieder & S. Sprenger. (2g(s) (DDB) Additional attachment(s) added on 9/24/2004 (Larson, Amy).

1 *Restricted*

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STIPULATION AND ORDER FOR EXTENSION OF TIME ( Judge Donovan W. Frank ) extension to 1/18/2 in which to answer or otherwise respond to pltf's complaint (2pg(s)(cc: all counsel) (DDB)

ATTORNEY APPEARANCE for deft J. Symchych, M. Raphan, H. Eng & M. Ginder. (1pg(s) (DDB)

STIPULATION AND ORDER GRANTING PERMISSION TO FILE MEMORANDA IN EXCESS OF 35 PAGES BUT NOT TO EXCEED 50 PAGES ( Judge Donovan W. Frank ) 1. That Cargill may file an original memorandum & reply memorandum in support of its motion to dismiss, the cumulative total of which shall not exceed 50 pages; & 2. That the Pltfs may file a memorandum in response to Cargill's motion to dismiss which shall not exceed 50 pages. (3pg(s)(cc: all counsel) (DDB)

ANSWER by deft. (30pg(s) (DDB)

NOTICE OF PRETRIAL CONFERENCE ( Magistrate Judge Arthur J. Boylan / 2/4/2) pretrial conference set for 9:30 a.m. on 3/26/02; Rule report ddl set for 3/19/02 (5pg(s) (cc: all counsel) (DDB)

PARTIAL MOTIONS by dft to dismiss, for summary judgment, and to strike ( to Judge Donovan W. Frank ) Ret. on 4/12/02 at 10:00am. 2pg(s) (PAK)

MEMORANDUM by dft in support of motion to dismiss [10-1], for summary judgment [10-2], and to strike [10-3] 36pg(s) (PAK)

AFFIDAVIT of Cindy Lehman regarding motion to dismiss [10-1], regarding motion for summary judgment [10-2], regarding motion to strike [10-3] 4pg(s) (PAK)

AFFIDAVIT of Michael Iwan regarding motion to dismiss [10-1], regarding motion for summary judgment [10-2], regarding motion to strike [10-3] 2+pg(s) (PAK)

AFFIDAVIT of Rick Dougherty regarding motion to dismiss [10-1], regarding motion for summary judgment [10-2], regarding motion to strike [10-3] 3pg(s) (PAK)

AFFIDAVIT of Sean Butler regarding motion to dismiss [10-1], regarding motion for summary judgment [10-2], regarding motion to strike [10-3] 2pg(s) (PAK)

AFFIDAVIT of Angela Nguyen regarding motion to dismiss [10-1], regarding motion for summary judgment [10-2], regarding motion to strike [10-3] 3pg(s) (PAK)

AFFIDAVIT of Monica Schulz regarding motion to dismiss [10-1], regarding motion for summary judgment [10-2], regarding motion to strike [10-3] 3pg(s) (PAK)

AFFIDAVIT of Peter Cochrane regarding motion to dismiss [10-1], regarding motion for summary judgment [10-2], regarding motion to strike [10-3] 3pg(s) (PAK)

AFFIDAVIT of Jill Dekraay regarding motion to dismiss [10-1], regarding motion for summary judgment [10-2], regarding motion to strike [10-3] 4pg(s) (PAK)

AFFIDAVIT of John Culmer regarding motion to dismiss [10-1], regarding motion for summary judgment [10-2], regarding motion to strike [10-3] 3pg(s) (PAK)

RESPONSE by plaintiff to motion to dismiss [10-1], to motion for summary judgment [10-2], to motion to strike [10-3] 35pg(s) (PAK)

DECLARATION of Lawrence P. Schaefer re motion to dismiss [10-1], re motion for summary judgment [10-2], re motion to strike [10-3] 4+pg(s) (PAK)

DECLARATION of Ronald Garrus re motion to dismiss [10-1], re motion for summary judgment [10-2], re motion to strike [10-3] 2pg(s) (PAK)

DECLARATION of Hollis Branham re motion to dismiss [10-1], re motion for summary judgment [10-2], re motion to strike [10-3] 7pg(s) (PAK)

DECLARATION of Toya Brown re motion to dismiss [10-1], re motion for summary judgment [10-2], re motion to strike [10-3] 4pg(s) (PAK)

DECLARATION of Charles Scott re motion to dismiss [10-1], re motion for summary judgment [10-2], re motion to strike [10-3] 5pg(s) (PAK)

DFT'S REPLY MEMORANDUM IN SUPPORT OF IT'S partial motion to dismiss [10-1], to motion for summary judgment [10-2], to motion to strike [10-3] 16pg(s) (PAK)

AFFIDAVIT of Michael Iwan regarding motion to dismiss [10-1], regarding motion for summary judgment [10-2], regarding motion to strike [10-3] 2pg(s) (PAK)

AFFIDAVIT of Peter Cochrane regarding motion to dismiss [10-1], regarding motion for summary judgment [10-2], regarding motion to strike [10-3] 2pg(s) (PAK)

SUPPLEMENTAL AFFIDAVIT of Angela Nguyen regarding motion to dismiss [10-1], regarding motion for summary judgment [10-2], regarding motion to strike [10-3] 2pg(s) (PAK)

AFFIDAVIT of Ozzie Morris regarding motion to dismiss [10-1], regarding motion for summary judgment [10-2], regarding motion to strike [10-3] 3pg(s) (PAK)

AFFIDAVIT of David A. Schimke regarding motion to dismiss [10-1], regarding motion for summary judgment [10-2], regarding motion to strike [10-3] 2+pg(s) (PAK)

REPORT OF RULE 26(f) MEETING by pltfs & deft. (10pg(s) (DDB)

PRETRIAL SCHEDULING ORDER ( Magistrate Judge Arthur J. Boylan / 3/26/2) amend pleadings, adding parties & discovery during the pre-class certificaiton portion shall be completed by 1/15/3. (3pg(s) (cc: counsel) (DDB)

NOTICE OF ATTORNEY WITHDRAWAL: terminating attorney David Lawrence Shulman for all pltfs. Attorney is no longer with the firm of Sprenger & Lang. (1pg(s) (DDB)

MINUTES:( Judge Donovan W. Frank / Bruce Tiffany) Deft's motion for partial dismissal [10-1] summary judgment [10-2] & to strike - Taken under advisement. Donovan W. Frank ) [10-3]. Parites may submit 2 to 3 page letter briefs on issue of extra territoral application of MHRA. (1pg(s) (DDB)

MINUTES:( Magistrate Judge Arthur J. Boylan / ) TELEPHONE CONFERENCE RE: DISCOVERY STATUS. (1pg(s) (DDB)

ORDER ( Magistrate Judge Arthur J. Boylan / 5/16/2) that 1.With respect to demographic information, Deft may limit production to race information, but may not limit said production to the races of African American & Caucasian; 2.With respect to employee complaints, Deft may limit its production to complaints of race discrimination & racial harassment, but may not limit said production to complaints by African American employees; & 3.Deft may exclude information relating to hourly employees. (2pg(s) (cc: all counsel) (DDB)

ORDER ( Magistrate Judge Arthur J. Boylan / 5/16/2) that 1.Stipulated Protective Order. Protective Order is granted in part. 2. Authorizations to Release Medical Records. Deft's request is granted in part. 3. Authorizations to Release Employment & Unemployment Compensation Records. Deft's request is granted in part. 4.Preservation of e-mail. Pltfs' request is granted. 5.Document Redaction. The Court will issue a separate written order on this issue. The parties may each submit a supplemental letter brief on this issue (limited to 5 pages) by 4:30 p.m. on Friday 5/10/2. 6. Next Status Conference. The next discovery management conference is set for 8:00 a.m. on Tuesday, 6/4/2. (15pg(s) (cc: all counsel) (DDB)

MINUTES:( Magistrate Judge Arthur J. Boylan / ) Telephone Conference re Discovery Issues. (1pg(s) (DDB)

ORDER ( Magistrate Judge Arthur J. Boylan / 6/5/2) that the Clerk of Court is directed to maintain the confidentiality of all documents filed in accordance with paragraph 9 of exhibit A. Whether the discovery period should begin on 6/1/94 or 1/1/92 shall be the subject of a formal motion practice. A hearing on said motion will be conducted before the undersigned commencing at 1:30 p.m. on Friday 6/21/2. Discovery Related to Salaried Non-Exempt Employees & Self-Critical Analysis Privilege will be addressed at the motions hearing scheduled to be heard on 6/21/2 at 1:30 p.m. (18pg(s) (cc: all counsel) (DDB)

MOTION by pltfs to compel discovery ( to Magistrate Judge Arthur J. Boylan ) ret. on 6/21/2 at 1:30 p.m. (3pg(s) (DDB)

MEMORANDUM by pltfs in support of their motion to compel discovery [42-1]. (57pg(s) (DDB)

MEMORANDUM by deft in support of its motion for protective order [44-1]. (13 pg(s) (DDB)

AFFIDAVIT of Tracie Haagensen regarding deft's motion for protective order [44-1]. (2pg(s) (DDB)

AFFIDAVIT of Karen Oberle regarding deft's motion for protective order [44-1]. (7pg(s) (DDB)

AFFIDAVIT of Holly S.A. Eng regarding deft's motion for protective order [44-1]. (5pg(s) (DDB)

MOTION by deft for protective order( to Magistrate Judge Arthur J. Boylan ) ret. on 6/21/2 at 1:30 p.m. (3pg(s) (DDB)

REPLY by deft to pltfs' motion to compel discovery [42-1]. (7pg(s) (DDB)

REPLY by pltfs to their motion to compel discovery [42-1]. (12pg(s) (DDB)

DECLARATION of Lawrence P. Schaefer in support of pltfs' reply to their motion to compel discovery [42-1]. (7pg(s) (DDB)

APPEAL by pltfs' from Magistrate Judge's Order dated 6/5/2( to Judge Donovan W. Frank ) [41-1]. (3pg(s) (DDB)

MEMORANDUM by pltfs in support of their appeal from the Magistrate Judge's Order dated 6/5/2 [52-1]. (13pg(s) (DDB)

DECLARATION of Lawrence P. Schaefer in support of pltfs' appeal from & objection to the Magistrate Judge's Order dated 6/5/2 [52-1], [52-1]. (82pg(s) (DDB)

MINUTES:( Magistrate Judge Arthur J. Boylan / ) Motions for discovery. (1pg(s) (DDB)

ORDER ON MOTION TO COMPEL & FOR PROTECTIVE ORDER (Magistrate Judge Arthur J. Boylan / 6/21/2) that 1. Pltfs' motion to compel discovery is granted in part & denied in part [42-1]. 2. Deft's motion for protective order barring the discovery herein requested by pltfs is granted in part & denied in part [44-1]. (2pg(s) (cc: all counsel) (DDB)

APPEAL from Magistrate Judge's Order dated 6/21/2 ( to Judge Donovan W. Frank ) [56-1]. (2pg(s) (DDB)

MEMORANDUM by deft in support of its APPEAL from Magistrate Judge's Order dated 6/21/2 [57-1]. (7pg(s) (DDB)

MINUTES:( Magistrate Judge Arthur J. Boylan / ) TELEPHONE CONFERENCE RE: DISCOVERY STATUS. (1pg(s) (DDB) Modified on 08/20/2002

ORDER AMENDING PRETRIAL SCHEDULING ORDER ( Magistrate Judge Arthur J. Boylan / 7/2/2) amending pleadings & adding parties is set for 3/17/03 (2pg(s) (cc: all counsel) (DDB)

MEMORANDUM OF LAW by defendant in opposition to APPEAL by pltfs' from Magistrate Judge's Order dated 6/5/02. [52-1] 14 pg(s) (JVN)

AFFIDAVIT of Michael Iwan regarding appeal by pltfs' from Magistrate Judge's Order dated 6/5/02. [52-1] 9 pg(s) (JVN)

OBJECTIONS & APPEAL from Magistrate Judge's Order (to Judge Donovan W. Frank ) by pltfs concerning order dated 6/21/2 [56-1]. (3pg(s) ( Modified on 07/08/2002

MEMORANDUM by pltfs in support of their APPEAL from Magistrate Judge's Order dated 6/21/2 [63-1]. (10pg(s) ( Modified on 07/08/2002

DECLARATION of Lawrence P. Schaefer in support of pltfs' APPEAL from Magistrate Judge's Order dated 6/21/2 [63-1]. (2pg(s) +EXHIBITS (SEPARATE) ( Modified on 07/08/2002

TRANSCRIPT OF Hearing held 6/4/2 before the Honorable Magistrate Judge Arthur J. Boylan ( Leslie R. Pingley). (SEPARATE) (DDB)

MEMORANDUM, OPINION, AND ORDER: ( Judge Donovan W. Frank / 7/15/2) that 1. deft's Partial Motion to Dismiss is GRANTED IN PART & DENIED IN PART [10-1]. 2. Deft's Motion for Partial Summary Judgment is GRANTED IN PART & DENIED IN PART [10-2]. 3. Deft's Motion to Strike is DENIED [10-3]. (17pg(s) (cc: all counsel) (DDB)

MEMORANDUM by pltf in opposition to deft's appeal motion from Magistrate Judge's Order [63-1]. (10 pg(s) (DDB)

DECLARATION of Susan M. Coler re pltf's memorandum in opposition to deft's APPEAL from Magistrate Judge's Order [63-1]. (45pg(s) (DDB)

MEMORANDUM by defendant in opposition to plaintiff's appeal from Magistrate Judge's Order of 6/21/02 denying motion to compel discovery related to salaried non-exempt employees and granting protective order [63-1] (9 pgs) (MKC)

TRANSCRIPT OF Hearing held 6/21/2 befoer the Honorable Magistrate Judge Arthur J. Boylan ( Leslie R. Pingley) (SEPARATE) (23pg(s) (DDB) Modified on 07/29/2002

ORDER ( Magistrate Judge Arthur J. Boylan / 8/9/02) that Plaintiff's motion to compel defendant to produce employee social secuurity numbers in it response to Plaintiffs' request for computerized date is GRANTED. The social security numbers will be produced for attorneys' eyes only as set out in the protecive order in this case. (2 pgs) (cc: all counsel) (MKC)

ATTORNEY SUBSTITUTION: terminating attorney Sara Louise Madsen for all pltfs in the above referenced matter. (1pg(s)(DDB) Modified on 09/12/2002

MEMORANDUM, OPINION, AND ORDER: ( Judge Donovan W. Frank / 8/19/2) that 1. Pltfs' appeal from Judge Boylan's 6/5/2 Order is GRANTED. 2. Pltfs' Appeal of Judge Boylan's 6/21/2 Order is GRANTED. 3. Deft's Appeal of Judge Boylan's 6/21/2 Order is DENIED & the portion of the 6/21/2 Order commencing the discovery period on 1/1/92 is AFFIRMED [63-1], [57-1], [52-1]. (8pg(s) (cc: all counsel) (DDB)

MINUTES:( Magistrate Judge Arthur J. Boylan / ) TELEPHONE CONRERENCE RE: DISCOVERY STATUS. (1 pg(s) (DDB)

MINUTES:( Magistrate Judge Arthur J. Boylan / ) Telephone Conference Re: Discovery status. Parties stipulated to amended scheduling order. Deft's informal discovery motion - taken under advisement. (1pg(s) (DDB)

ORDER AMENDING PRETRIAL SCHEDULING ORDER ( Magistrate Judge Arthur J. Boylan / 10/1/2). (2 pg(s) (cc: all counsel) (DDB)

ORDER ( Magistrate Judge Arthur J. Boylan / 10/1/2) that pltf shall fully & completely answer Interrogatory #s 1 & 8. (2pg(s) (cc: all counsel) (DDB)

ATTORNEY SUBSTITUTION: terminating attorney Lisa C Stratton for all pltfs. No longer with the firm of Sprenger & Lang per her letter to the court dated 10/4/2. (1pg(s) (DDB)

MOTION by deft for order for certification ( to Judge Donovan W. Frank ) (2pg(s) (DDB)

MEMORANDUM by deft in support of its motion for order for certification [80-1]. (16pg(s) (DDB)

AFFIDAVIT of Katie Pfeifer regarding deft's motion for order for certification [80-1]. (9pg(s) (DDB)

AFFIDAVIT of Robert Topel regarding deft's motion for order for certification [80-1]. SEALED (SEPARATE) (DDB)

RESPONSE by pltfs to deft's motion for order for certification of interlocutory appeal [80-1]. (11pg(s) (DDB)

REPLY by deft in support of its motion for certification [80-1] (11pg(s) (DDB)

MINUTES:( Magistrate Judge Arthur J. Boylan ) Monthly conference (by telephone ) re: discovery. Matters taken under advisement. Order to follow. 1 pg(s) (VEM)

ORDER ( Magistrate Judge Arthur J. Boylan ) Pltf shall full and completely answer Interrogatory No. 1 of Cargill's Interrogatories to Pltf's Set III. Pltfs shall identify portions of the transcript where attorney client privilege was invoked and parties other than that deponent and counsel were present. Pltf's shall reveal the identity of third parties present during said conversations. 3 pg(s) (cc: all counsel) (VEM)

MEMORANDUM, OPINION, AND ORDER: ( Judge Donovan W. Frank ) deft's motion for certification is denied. [80-1] 3 pg(s) (cc: all counsel) (VEM)

RULE 7.1 DISCLOSURE STATEMENT by defendant Cargill Incorporated that none exist 2pg(s) (JMH)

LETTER dated 2/3/03 from Susan M. Coler requesting Sara Madsen's name be removed from representing plaintiffs as she is no longer with the law firm of Sprenger & lang 1pg(s) (DFL)

MINUTES OF TELEPHONE CONFERENCE: ( Magistrate Judge Arthur J. Boylan ), Re: discovery status 1pg(s) (DFL)

ORDER ( Magistrate Judge Arthur J. Boylan / 3/19/03) the subpoena issued to Bill Douglas shall remain in full force and effect; defendant file brief concerning any issues that it believes will arise on or before 4/18/03; plaintiff file reply brief on or before 5/2/03 hearing set for 10:00 a.m. on 5/9/03 2pg(s) (cc: all counsel) (DFL)

MOTION by defendant for order to overcome attorney-client privilege and work product claims of R. Bill Douglas and others, and to amend pretrial schedule.( to Magistrate Judge Arthur J. Boylan ) ret. 5/9/03 at 10:00am. 4pg(s) (RJL) Modified on 06/26/2003

MEMORANDUM by defendant in support of motion for order to overcome attorney-client privilege and work product claims of R. Bill Douglas and others [93-1], of motion to amend pretrial schedule. [93-2] 24pg(s) (RJL)

AFFIDAVIT of Frederick L. Budde regarding motion for order to overcome attorney-client privilege and work product claims of R. Bill Douglas and others [93-1], regarding motion to amend pretrial schedule. [93-2] 4pg(s) (RJL)

AFFIDAVIT of Matthew E. Klein regarding motion for order to overcome attorney-client privilege and work product claims of R. Bill Douglas and others [93-1], regarding motion to amend pretrial schedule. [93-2] 5+pg(s) (SEPARATE) (RJL)

MEMORANDUM by plaintiff in support of motion for protective order. (SEPARATE & SEALED) (RJL)

MEMORANDUM by plaintiff in opposition to motion for order to overcome attorney-client privilege and work product claims of R. Bill Douglas and others [93-1], to motion to amend pretrial schedule. [93-2] (SEPARATE & SEALED) (RJL)

DECLARATION of Lawrence P. Schaefer in proceedings regarding deposition of R. Bill Douglas. (SEPARATE & SEALED) (RJL)

MOTION by defendant to quash, and/or to limit discovery by deposition regarding the putative deposition of Whitney MacMillan (to Magistrate Judge Arthur J. Boylan). ret 5/21/03 at 1:30 pm 1 pg(s) (JVN)