Case: Cahill v. Nike, Inc.

Cahill v. Nike

Cahill v. Nike Inc

Cahill v. Nike Inc

Cahill v. Nike Inc

Complaint. Filing fee in the amount of $400 collected. Agency Tracking ID: 0979-5514167 Jury Trial Requested: Yes. Filed by Sara Johnston, Kelly Cahill against Nike, Inc. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Civil Cover Sheet, # 4 Proposed Summons). (Salerno Owens, Laura) (Entered: 08/09/2018)

1 Exhibit A

View on PACER

2 Exhibit B

View on PACER

3 Civil Cover Sheet

View on PACER

4 Proposed Summons

View on PACER

Consent to Join Law Suit . Filed by Kelly Cahill, Sara Johnston. (Salerno Owens, Laura) (Entered: 08/09/2018)

Consent to Join Law Suit . Filed by Kelly Cahill, Sara Johnston. (Salerno Owens, Laura) (Entered: 08/09/2018)

Motion for Leave to Appear Pro Hac Vice for Attorney Laura L. Ho . Filing fee in the amount of $300 collected; Agency Tracking ID: 0979-5519355. Filed by Kelly Cahill, Sara Johnston. (Salerno Owens, Laura) (Entered: 08/15/2018)

Motion for Leave to Appear Pro Hac Vice for Attorney Byron Goldstein . Filing fee in the amount of $300 collected; Agency Tracking ID: 0979-5519386. Filed by Kelly Cahill, Sara Johnston. (Salerno Owens, Laura) (Entered: 08/15/2018)

Motion for Leave to Appear Pro Hac Vice for Attorney Katharine L. Fisher . Filing fee in the amount of $300 collected; Agency Tracking ID: 0979-5519395. Filed by Kelly Cahill, Sara Johnston. (Salerno Owens, Laura) (Entered: 08/15/2018)

Notice of Case Assignment to Magistrate Judge Paul Papak and Discovery and Pretrial Scheduling Order. NOTICE: Counsel shall print and serve the summonses and all documents issued by the Clerk at the time of filing upon all named parties in accordance with Local Rule 3-5. Discovery is to be completed by 12/14/2018. Joint Alternate Dispute Resolution Report is due by 1/14/2019. Pretrial Order is due by 1/14/2019. Ordered by Magistrate Judge Paul Papak. (jtj) (Entered: 08/16/2018)

Summons Issued Electronically as to Nike, Inc.. NOTICE: Counsel shall print and serve the summonses and all documents issued by the Clerk at the time of filing upon all named parties in accordance with Local Rule 3-5. (jtj) (Entered: 08/16/2018)

ORDER: Granting Application for Special Admission Pro Hac Vice of Laura L. Ho for Kelly Cahill and Sara Johnston. Application Fee in amount of $300 collected. Receipt No. 0979-55193 issued. Signed on 8/16/2018 by Magistrate Judge Paul Papak. (ecp) (Entered: 08/20/2018)

Notification of CM/ECF Account for Laura L. Ho (Pro Hac Vice admission). Your login is: llho. Go to the CM/ECF login page to set your password. (ecp) (Entered: 08/20/2018)

ORDER: Granting Application for Special Admission Pro Hac Vice of Byron Goldstein for Kelly Cahill and Sara Johnston. Application Fee in amount of $300 collected. Receipt No. 0979-5519386 issued. Signed on 8/16/2018 by Magistrate Judge Paul Papak. (ecp) (Entered: 08/20/2018)

Notification of CM/ECF Account for Byron Goldstein (Pro Hac Vice admission). Your login is: bgoldstein. Go to the CM/ECF login page to set your password. (ecp) (Entered: 08/20/2018)

ORDER: Granting Application for Special Admission Pro Hac Vice of Katharine L. Fisher for Kelly Cahill and for Sara Johnston. Application Fee in amount of $300 collected. Receipt No. 0979-5519395 issued. Signed on 8/16/2018 by Magistrate Judge Paul Papak. (ecp) (Entered: 08/20/2018)

Motion for Leave to Appear Pro Hac Vice for Attorney India Lin Bodien . Filing fee in the amount of $300 collected; Agency Tracking ID: 0979-5521290. Filed by Kelly Cahill, Sara Johnston. (Salerno Owens, Laura) (Entered: 08/17/2018)

Motion for Leave to Appear Pro Hac Vice for Attorney Craig Ackermann . Filing fee in the amount of $300 collected; Agency Tracking ID: 0979-5521292. Filed by Kelly Cahill, Sara Johnston. (Salerno Owens, Laura) (Entered: 08/17/2018)

ORDER: Granting Application for Special Admission Pro Hac Vice of India Lin Bodien for Kelly Cahill and Sara Johnston. Application Fee in amount of $300 collected. Receipt No. 0979-5521290 issued. Signed on 8/22/2018 by Magistrate Judge Paul Papak. (jtj) (Entered: 08/23/2018)

Notification of CM/ECF Account for India Lin Bodien (Pro Hac Vice admission). Your login is: ilbodien. Go to the CM/ECF login page to set your password. (jtj) (Entered: 08/23/2018)

ORDER: Granting Application for Special Admission Pro Hac Vice of Craig Ackermann for Kelly Cahill and Sara Johnston. Application Fee in amount of $300 collected. Receipt No. 0979-5521292 issued. Signed on 8/22/2018 by Magistrate Judge Paul Papak. (jtj) (Entered: 08/23/2018)

Notification of CM/ECF Account for Craig Ackermann (Pro Hac Vice admission). Your login is: cackermann. Go to the CM/ECF login page to set your password. (jtj) (Entered: 08/23/2018)

Consent to Join Law Suit of Lindsay Elizabeth. Filed by Kelly Cahill, Sara Johnston. (Ho, Laura) (Entered: 08/24/2018)

Affidavit of Service of Summons Issued 8 upon Nike, Inc. served on 8/16/2018 Filed by Sara Johnston; Kelly Cahill. (Salerno Owens, Laura) (Entered: 08/27/2018)

Motion for Extension of Time to Answer Plaintiffs' Class Action Complaint. Filed by Nike, Inc.. (Pedersen, Amy) (Entered: 08/29/2018)

Corporate Disclosure Statement . Filed by Nike, Inc.. (Pedersen, Amy) (Entered: 08/29/2018)

Motion for Leave to Appear Pro Hac Vice for Attorney Daniel Prince . Filing fee in the amount of $300 collected; Agency Tracking ID: 0979-5536400. Filed by Nike, Inc.. (Pedersen, Amy) (Entered: 08/29/2018)

Motion for Leave to Appear Pro Hac Vice for Attorney Zachary P. Hutton . Filing fee in the amount of $300 collected; Agency Tracking ID: 0979-5536405. Filed by Nike, Inc.. (Pedersen, Amy) (Entered: 08/29/2018)

Motion for Leave to Appear Pro Hac Vice for Attorney Felicia A. Davis . Filing fee in the amount of $300 collected; Agency Tracking ID: 0979-5536414. Filed by Nike, Inc.. (Pedersen, Amy) (Entered: 08/29/2018)

A duplicate payment in the amount of $300.00 was submitted by Nike, Inc. in the above-referenced case. For information on refund procedures, visit Requesting a Refund of Electronically Paid Fees on the Court website. Refund Request is Due 9/10/2018. (ljp) (Entered: 08/30/2018)

ORDER issued by Magistrate Judge Paul Papak: Granting Defendant's Unopposed Motion for Extension of Time 22 as follows: Answer deadline reset to 11/5/2018 for Defendant Nike Inc. (gm) (Entered: 08/30/2018)

ORDER: Granting Application for Special Admission Pro Hac Vice of Daniel Prince for Nike, Inc.. Application Fee in amount of $300 collected. Receipt No. 0979-5536400 issued. Signed on 8/30/2018 by Magistrate Judge Paul Papak. (ecp) (Entered: 08/30/2018)

Notification of CM/ECF Account for Daniel Prince (Pro Hac Vice admission). Your login is: dprince. Go to the CM/ECF login page to set your password. (ecp) (Entered: 08/30/2018)

ORDER: Granting Application for Special Admission Pro Hac Vice of Zachary P. Hutton for Nike, Inc.. Application Fee in amount of $300 collected. Receipt No. 0979-5536405 issued. Signed on 8/30/2018 by Magistrate Judge Paul Papak. (ecp) (Entered: 08/30/2018)

Notification of CM/ECF Account for Zachary P. Hutton (Pro Hac Vice admission). Your login is: zphutton. Go to the CM/ECF login page to set your password. (ecp) (Entered: 08/30/2018)

ORDER: Granting Application for Special Admission Pro Hac Vice of Felicia A. Davis for Nike, Inc.. Application Fee in amount of $300 collected. Receipt No. 0979-5536414 issued. Signed on 8/30/2018 by Magistrate Judge Paul Papak. (ecp) (Entered: 08/30/2018)

Notification of CM/ECF Account for Felicia A. Davis (Pro Hac Vice admission). Your login is: fadavis. Go to the CM/ECF login page to set your password. (ecp) (Entered: 08/30/2018)

Consent to Join Law Suit of Meghan Grieve. Filed by Kelly Cahill, Sara Johnston. (Salerno Owens, Laura) (Entered: 09/13/2018)

Notice of Case Reassignment: This case has been reassigned from Magistrate Judge Paul Papak to Magistrate Judge Jolie A. Russo. (eo) (Entered: 09/20/2018)

Consent to Join Law Suit of Paige Azavedo. Filed by All Plaintiffs. (Salerno Owens, Laura) (Entered: 10/29/2018)

Motion to Dismiss for Failure to State a Claim and/or Strike Plaintiffs' Class and Collective Allegation Complaint. Oral Argument requested. Filed by Nike, Inc.. (Davis, Felicia) (Entered: 11/05/2018)

ORDER issued by Magistrate Judge Jolie A. Russo: Setting Defendant Nike's Partial Motion to Dismiss and/or to Strike Plaintiffs' Class and Collective Action Allegation Complaint 38 on the under advisement calendar of 12/10/2018. The request for oral argument will be considered in due course. Should the Court deem the motion(s) appropriate for disposition with oral argument upon review of the briefings, the motion(s) will be scheduled accordingly. (gm) (Entered: 11/06/2018)

Consent to Join Law Suit (Consent to Become Party Plaintiff in Collective Action Under 29 U.S.C. Section 216(b). Filed by All Plaintiffs. (Salerno Owens, Laura) (Entered: 11/08/2018)

ORDER issued by Magistrate Judge Jolie A. Russo: Resetting Defendant Nike's Partial Motion to Dismiss and/or to Strike Plaintiffs' Class and Collective Action Allegation Complaint 38 from the under advisement calendar of 12/10/2018 to the telephonic oral argument calendar of 12/17/2018 at 10:00AM in Portland Chambers before Magistrate Judge Jolie A. Russo. (gm) (Entered: 11/09/2018)

First Amended Complaint (CLASS AND COLLECTIVE ACTION ALLEGATION ). Filed by Sara Johnston, Kelly Cahill, Lindsay Elizabeth, Heather Hender against Nike, Inc.. (Ho, Laura) (Entered: 11/19/2018)

Consent to Join Law Suit by Heather Hender. Filed by Kelly Cahill, Lindsay Elizabeth, Heather Hender, Sara Johnston. (Ho, Laura) (Entered: 11/19/2018)

Joint Motion To Modify Briefing Schedule. Filed by Nike, Inc.. (Davis, Felicia) (Entered: 11/21/2018)

ORDER issued by Magistrate Judge Jolie A. Russo: Granting the parties' Joint Motion to Modify Briefing Schedule 44 as follows: Defendant's Answer or other responsive pleading due by 12/10/2018. Response to any responsive pleading due by 1/14/2019. Reply to response to any responsive pleading due by 1/30/2019. Order: Defendant Nike's Partial Motion to Dismiss and/or to Strike Plaintiffs' Class and Collective Action Allegation Complaint 38 is Denied as Moot and the telephonic oral argument which was set for 12/17/2018 at 10:00AM is Stricken. Counsel are reminded to include the judge's initials 'JR' following the case number on all future pleadings. (gm) (Entered: 11/26/2018)

Unopposed Motion to Vacate Deadlines. Filed by Kelly Cahill, Lindsay Elizabeth, Heather Hender, Sara Johnston. (Ho, Laura) (Entered: 12/10/2018)

Motion to Dismiss First Amended Class and Collective Action Allegation Complaint Filer is subject to the requirements of Fed. R. Civ. P. 7.1. Oral Argument requested. Filed by Nike, Inc.. (Davis, Felicia) (Entered: 12/10/2018)

ORDER issued by Magistrate Judge Jolie A. Russo: Granting Plaintiffs' Unopposed Motion to Vacate Deadlines 46 as follows and as modified: The current case management deadlines are Stayed. The court will schedule a Rule 16 Conference following final ruling on the partial motion to dismiss 47 . (gm) (Entered: 12/11/2018)

1 - Scheduling

ORDER issued by Magistrate Judge Jolie A. Russo: Setting Defendant's Partial Motion to Dismiss First Amended Class and Collective Action Allegation Complaint 47 on the Telephonic Oral Argument Calendar of 2/19/2019 at 10:00AM in Portland Chambers before Magistrate Judge Jolie A. Russo. (gm) (Entered: 12/11/2018)

Motion for Leave to Appear Pro Hac Vice for Attorney Barry Goldstein . Filing fee in the amount of $300 collected; Agency Tracking ID: 0979-5671977. Filed by All Plaintiffs. (Salerno Owens, Laura) (Main Document 50 replaced on 12/17/2018) (cw). (Entered: 12/17/2018)

Motion for Leave to Appear Pro Hac Vice for Attorney James P. Kan . Filing fee in the amount of $300 collected; Receipt No.: 26E5UIN4. Filed by All Plaintiffs. (Salerno Owens, Laura) (Entered: 12/17/2018)

Clerk's Notice of Docket Correction regarding 50 Motion to Appear Pro Hac Vice. A corrected PDF has been uploaded and has replaced the incorrect attachment. The original PDF contained a clerical error on page 1 - listing the parties to be represented. The Notice of Electronic Filing will be regenerated to all parties. (cw) (Entered: 12/17/2018)

ORDER: Granting Application for Special Admission Pro Hac Vice of Barry Goldstein for Kelly Cahill, Lindsay Elizabeth, Heather Hender, and Sara Johnston. Application Fee in amount of $300 collected. Receipt No. 0979-5671977 issued. Signed on 12/18/2018 by Magistrate Judge Jolie A. Russo. (ecp) (Entered: 12/18/2018)

Notification of CM/ECF Account for Barry Goldstein (Pro Hac Vice admission). Your login is: goldsteinb. Go to the CM/ECF login page to set your password. (ecp) (Entered: 12/18/2018)

ORDER: Granting Application for Special Admission Pro Hac Vice of James P. Kan for Kelly Cahill, Lindsay Elizabeth,Heather Hender, and Sara Johnston. Application Fee in amount of $300 collected. Receipt No. 26E5UIN4 issued. Signed on 12/18/2018 by Magistrate Judge Jolie A. Russo. (ecp) (Entered: 12/18/2018)

Notification of CM/ECF Account for James P. Kan (Pro Hac Vice admission). Your login is: jpkan. Go to the CM/ECF login page to set your password. (ecp) (Entered: 12/18/2018)

Notice of Appearance of Brittany M. Simpson appearing on behalf of All Plaintiffs Filed by on behalf of All Plaintiffs. (Simpson, Brittany) (Entered: 01/14/2019)

Response in Opposition to Motion to Dismiss First Amended Class and Collective Action Allegation Complaint Filer is subject to the requirements of Fed. R. Civ. P. 7.1 47 Oral Argument requested. Filed by All Plaintiffs. (Goldstein, Byron) (Entered: 01/14/2019)

Notice re Motion to Dismiss 47 Filed by Kelly Cahill, Lindsay Elizabeth, Heather Hender, Sara Johnston. (Related document(s): Motion to Dismiss 47 .) (Attachments: # 1 Errata Corrected Opposition to Defendant's Partial Motion to Dismiss) (Goldstein, Byron) (Entered: 01/16/2019)

Consent to Join Law Suit of Lauren Anderson. Filed by All Plaintiffs. (Salerno Owens, Laura) (Entered: 01/18/2019)

Notice - Opt-Out Form of Meghan Grieve Filed by All Plaintiffs. (Salerno Owens, Laura) (Entered: 01/18/2019)

Reply to Motion to Dismiss First Amended Class and Collective Action Allegation Complaint Filer is subject to the requirements of Fed. R. Civ. P. 7.1 47 Oral Argument requested. Filed by Nike, Inc.. (Davis, Felicia) (Entered: 01/30/2019)

MINUTES OF PROCEEDINGS before Magistrate Judge Jolie A. Russo: Oral Argument held 2/19/19. Order: Defendant's Partial Motion to Dismiss First Amended Class and Collective Action Allegation Complaint 47 is taken under advisement as of 2/19/2019. James Kan; Laura Salerno Owens present as counsel for plaintiff(s). Felicia Davis; Daniel Prince; Amy Joseph Pedersen present as counsel for defendant(s). Tape No: FTR-10B. (gm) (Entered: 02/19/2019)

Findings & Recommendation: Defendant's partial Motion to Dismiss or alternatively to Strike 47 should be denied. Signed on 2/26/19 by Magistrate Judge Jolie A. Russo. (gm) (Entered: 02/26/2019)

ORDER issued by Magistrate Judge Jolie A. Russo: Findings & Recommendation 64 is referred to Judge Marco A. Hernandez for review. The parties shall have fourteen (14) days from the date of service of a copy of this recommendation within which to file specific written objections with the court. Thereafter, the parties shall have fourteen (14) days within which to file a response to the objections. (gm) (Entered: 02/26/2019)

Consent to Join Law Suit by Cindy Linebaugh. Filed by All Plaintiffs. (Salerno Owens, Laura) (Entered: 03/18/2019)

Consent to Join Law Suit by Marissa Stromgren. Filed by All Plaintiffs. (Salerno Owens, Laura) (Entered: 04/12/2019)

Joint ADR Report . Filed by Nike, Inc. (Prince, Daniel) Modified on 4/29/2019 to clarify docket text (jn). (Entered: 04/26/2019)

Fed. R. Civ. P. 26(a)(1) Agreement . Filed by Nike, Inc.. (Prince, Daniel) (Entered: 04/26/2019)

Joint Status Report, Rule 26(f) Report and Discovery Plan . Filed by Nike, Inc.. (Prince, Daniel) (Entered: 04/26/2019)

Joint Stipulation and Proposed Order re eDiscovery by Nike, Inc.. Filed by Nike, Inc.. (Attachments: # 1 Exhibit A&B to Joint Stipulation and Proposed Order re eDiscovery) (Prince, Daniel) (Entered: 04/26/2019)

JOINT STIPULATION AND ORDER REGARDING E-DISCOVERY. Signed on 4/28/19 by Magistrate Judge Jolie A. Russo. (gm) (Entered: 04/29/2019)

Notice of Attorney Withdrawal: Brittany Simpson Filed by All Plaintiffs. (Wilson, Harry) (Entered: 05/10/2019)

ORDER: Adopting the Magistrate's Findings and Recommendation 64 . Defendant's Partial Motion to Dismiss Plaintiffs' First Amended Class and Collective Action Allegation Complaint 47 is Denied. Signed on 5/16/19 by Judge Marco A. Hernandez. (gm) (Entered: 05/20/2019)

Answer to 42 Amended Complaint . Filed by Nike, Inc.. (Davis, Felicia) (Entered: 05/30/2019)

ORDER issued by Magistrate Judge Jolie A. Russo: Setting a Telephonic Rule 16 Conference for 6/17/2019 at 10:00AM in Portland Chambers before Magistrate Judge Jolie A. Russo. Local Rules 16-2(b) and 26-1 require that counsel confer prior to the conference. At the conference, counsel should be prepared to discuss the status of the case, relevant dates and deadlines, and any other significant issues. If consents are going to be filed, it is helpful if they are filed prior to the time of the conference, particularly if a firm trial date is desired. The court is aware of the parties' earlier-filed Rule 26(f) Report and Discovery Plan and the parties may consider filing a revised Rule 26(f) Report and Discovery Plan, if necessary, prior to the Rule 16 Conference. (gm) (Entered: 05/30/2019)

1 - Scheduling

Supplemental Rule 26(f) Report and Discovery Plan . Filed by Nike, Inc.. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E) (Prince, Daniel) (Entered: 06/14/2019)

1 Exhibit A

View on PACER

2 Exhibit B

View on PACER

3 Exhibit C

View on PACER

4 Exhibit D

View on PACER

5 Exhibit E

View on PACER

Rule 26(f) Report and Discovery Plan Addendum. Filed by Kelly Cahill, Lindsay Elizabeth, Heather Hender, Sara Johnston. (Goldstein, Byron) (Entered: 06/14/2019)

Supplement Nike's Response to Pls. Addendum to Parties' Joint Supplemental R. 26(f) Report. Filed by Nike, Inc.. (Prince, Daniel) (Entered: 06/14/2019)

MINUTES OF PROCEEDINGS before Magistrate Judge Jolie A. Russo: Telephonic Rule 16 Conference held 6/17/19. Order: Setting a further Telephonic Status/Scheduling Conference for 9/16/2019 at 1:30PM in Portland Chambers before Magistrate Judge Jolie A. Russo. Discovery is continued to 9/16/2019. James Kan; Laura Salerno Owens present as counsel for plaintiff(s). Amy Joseph Petersen; Daniel Prince; Felicia Davis present as counsel for defendant(s). Court Reporter: (None). (gm) (Entered: 06/17/2019)

Scheduling Conference

1 - Scheduling

ORDER issued by Magistrate Judge Jolie A. Russo: The Court orders that defendants Ex. C (doc. 77 -3) will be entered as the parties Protective Order. The parties may challenge any discovery AEO designation made pursuant to the Protective Order. (gm) (Entered: 06/17/2019)

PROTECTIVE ORDER. Signed on 6/17/19 by Magistrate Judge Jolie A. Russo. (gm) (Entered: 06/17/2019)

Notice of Appearance of Chad A. Naso appearing on behalf of All Plaintiffs Filed by on behalf of All Plaintiffs. (Naso, Chad) (Entered: 06/19/2019)

Notice of Change of Address Filed by All Plaintiffs. (Salerno Owens, Laura) (Entered: 07/18/2019)

Joint Status Report . Filed by Nike, Inc.. (Prince, Daniel) (Entered: 09/13/2019)

MINUTES of Proceedings: Telephonic Status/Scheduling Conference held on 9/16/2019. Order: Setting a further Telephonic Status/Scheduling Conference for Monday, 12/16/2019 at 1:30PM (by telephone) before Magistrate Judge Jolie A. Russo. James Kan and Laura Salerno Owens present as counsel for plaintiffs. Daniel Prince and Felicia Davis present as counsel for defendant. Court Reporter: None. Magistrate Judge Jolie A. Russo presiding. (pvh) (Entered: 09/16/2019)

Scheduling Conference

ORDER issued by Magistrate Judge Jolie A. Russo: Setting a Telephone Conference re: discovery issues for 10/30/2019 at 10:00AM in Portland Chambers before Magistrate Judge Jolie A. Russo. (gm) (Entered: 10/11/2019)

1 - Scheduling

MINUTES OF PROCEEDINGS before Magistrate Judge Jolie A. Russo: Telephone Conference re: discovery issues held 10/30/19. Discovery matters taken under advisement. Byron Goldstein; Laura Ho; Chad Naso present as counsel for plaintiff(s). Daniel Prince; Felicia Davis present as counsel for defendant(s). Tape No: FTR-10B. (gm) (Entered: 10/30/2019)

Discovery Hearing

ORDER issued by Magistrate Judge Jolie A. Russo: After considering the parties' comprehensive briefing and oral argument on October 30, 2019, plaintiffs' September 27, 2019 letter request to the Court to compel precertification discovery is Granted in Part and Denied in Part as follows: 1) With respect to Nike's Public Statements on Discrimination (RFPs 39-43 and 47), Nike shall produce the statements themselves and the motion is denied with respect to any further documentation regarding the public statements. However, to the extent not already produced, Nike shall produce any uniform policies it maintained during the relevant time periods regarding hiring, firing, pay, promotions, and compensation systems; 2) With respect to documents concerning sex discrimination, harassment, and hostile work environment complaints (RFPs 27, 29, and 45-46), the motion is granted regarding any such complaints made by any named plaintiff or those putative plaintiffs who have already consented to join and any other complainants to the extent such complaints involve compensation, promotion, or performance reviews and specific complaints that male colleagues received favorable treatment in those areas for the same work; 3) With respect to the personnel records of former Nike executives Trevor Edwards, Daniel Tawiah, and David Ayre (RFPs 34-38), the motion is granted to the extent the records contain complaints of sexual harassment/discrimination linked to policies of pay/promotions and job duties either by the named executives themselves or regarding actions these executives may have taken to condone pay/promotion and job duty discrimination decisions of lower level managers; and 4) With respect to insurance policies (RFP 51) the motion is denied. All production pursuant to this motion is subject to the Protective Order 82 entered in this case on June 17, 2019, as relevant and necessary. (gm) (Entered: 10/31/2019)

1 - Scheduling

Joint Status Report . Filed by Kelly Cahill, Lindsay Elizabeth, Heather Hender, Sara Johnston. (Goldstein, Byron) (Entered: 12/12/2019)

MINUTES OF PROCEEDINGS before Magistrate Judge Jolie A. Russo: Telephonic Status Conference held 12/16/19. Order: Setting a further Telephonic Status/Scheduling Conference for 3/16/2020 at 1:30PM in Portland Chambers before Magistrate Judge Jolie A. Russo. Laura Salerno Owens; James Kan present as counsel for plaintiff(s). Daniel Prince; Felicia Davis present as counsel for defendant(s). Court Reporter: (None). (gm) (Entered: 12/16/2019)

Status Conference