Case: EEOC v. TEAMSTERS LOCAL 804

EEOC v. Teamsters Local 804

EEOC v. Teamsters Local 804

EEOC v. Teamsters Local 804

EEOC v. Teamsters Local 804

EEOC v. Teamsters Local 804

EEOC v. Teamsters Local 804

Carly Knight, Frank Dobbin, Alexandra Kalev

COMPLAINT against Teamsters Local 804. Document filed by Equal Employment Opportunity Commission.(jjm, ) Additional attachment(s) added on 3/29/2004 (jjm, ). (Entered: 03/29/2004)

SUMMONS ISSUED as to Teamsters Local 804. (jjm, ) (Entered: 03/29/2004)

Magistrate Judge Frank Maas is so designated. (jjm, ) (Entered: 03/29/2004)

Case Designated ECF. (jjm, ) (Entered: 03/29/2004)

SUMMONS ISSUED as to Teamsters Local 804. (jjm, )

Magistrate Judge Frank Maas is so designated. (jjm, )

Case Designated ECF. (jjm, )

PRELIMINARY PRETRIAL ORDER Pretrial Conference set for 6/30/2004 10:00 AM before Judge Laura Taylor Swain, in Courtroom No. 444, 40 Foley Square, NY, NY; (Signed by Judge Laura Taylor Swain on 04/06/04) Copies forwarded by CHambers.(djc, ) (Entered: 04/07/2004)

STIPULATION AND ORDER; that the time for defendant to answer or otherwise move with respect to the Complaint in this action is extended to 6/15/04. (Signed by Judge Laura Taylor Swain on 6/2/04) Copies Faxed By Chambers.(sac, ) (Entered: 06/03/2004)

Set Answer Due Date purs. to 3 Stipulation and Order as to Teamsters Local 804 answer due on 6/15/2004. (sac, ) (Entered: 06/03/2004)

Set Answer Due Date purs. to 3 Stipulation and Order as to Teamsters Local 804 answer due on 6/15/2004. (sac, )

MOTION to Dismiss and Notice to Motion of Defendant Teamsters 804 to Dismiss the Compliant. Document filed by Teamsters Local 804. Responses due by 6/29/2004 Return Date set for 7/7/2004 02:00 PM. (Attachments: # 1 Declaration of Richard A. Brook# 2 Exhibit A# 3 Exhibit B)(Brook, Richard) (Entered: 06/15/2004)

BRIEF re: 4 MOTION to Dismiss and Notice to Motion of Defendant Teamsters 804 to Dismiss the Compliant.. Document filed by Teamsters Local 804. (Attachments: # 1 Addendum cover and contents page# 2 Addendum Item 1# 3 Addendum Item 2# 4 Addendum Item 3)(Brook, Richard) (Entered: 06/15/2004)

ENDORSED LETTER addressed to Judge Laura Taylor Swain from Richard Brook dated 6/3/04; Re: Pretrial Conference set for 10/14/2004 at 2:00 PM before Judge Laura Taylor Swain, and the related deadlines are modified accordingly. (Signed by Judge Laura Taylor Swain on 6/24/04) Copies Faxed By Chambers.(sac, ) (Entered: 06/25/2004)

CERTIFICATE OF SERVICE of June 24, 2004 Memo Endorsement served on Katherine E. Bissell, Elizabeth Grossman and Adela P. Santos on June 25, 2004. Document filed by Teamsters Local 804. (Brook, Richard) (Entered: 06/25/2004)

ENDORSED LETTER re: 4 MOTION to Dismiss and Notice to Motion of Defendant Teamsters 804 to Dismiss the Compliant. filed by Teamsters Local 804 addressed to Judge Laura Taylor Swain from Adela P. Santos dated 6/28/04, Set Deadlines/Hearing as to 4 MOTION to Dismiss and Notice to Motion of Defendant Teamsters 804 to Dismiss the Compliant.:The requested extensions are granted. Responses due by 7/2/2004; Replies due by 7/12/2004. (Signed by Judge Laura Taylor Swain on 6/28/04) Copies Faxed By Chambers.(sac, ) (Entered: 06/29/2004)

MEMORANDUM OF LAW in Opposition re: 4 MOTION to Dismiss and Notice to Motion of Defendant Teamsters 804 to Dismiss the Compliant.. Document filed by Equal Employment Opportunity Commission. (Santos, Adela) (Entered: 07/02/2004)

AFFIDAVIT of Adela Santos in Support re: 4 MOTION to Dismiss and Notice to Motion of Defendant Teamsters 804 to Dismiss the Compliant.. Document filed by Equal Employment Opportunity Commission. (Santos, Adela) (Entered: 07/02/2004)

REPLY MEMORANDUM OF LAW in Support re: 4 MOTION to Dismiss and Notice to Motion of Defendant Teamsters 804 to Dismiss the Compliant.. Document filed by Teamsters Local 804. (Brook, Richard) (Entered: 07/12/2004)

ENDORSED LETTER addressed to Judge Swain from Richard Brook dated 10/05/04 re: the (pre-trial) conference is adjourned to November 19, 2004 at 11:00 a.m. and the related deadlines are modified accordingly; (Signed by Judge Laura Taylor Swain on 10/6/04) (djc, ) (Entered: 10/07/2004)

Set Deadlines/Hearings: Pretrial Conference set for 11/19/2004 11:00 AM before Judge Laura Taylor Swain. (djc, ) (Entered: 10/07/2004)

Set Deadlines/Hearings: Pretrial Conference set for 11/19/2004 11:00 AM before Judge Laura Taylor Swain. (djc, )

CERTIFICATE OF SERVICE of Memo Endorsement served on Katherine E. Bissell, Elizabeth Grossmand and Adela P. Santos on October 7, 2004. Document filed by Teamsters Local 804. (Brook, Richard) (Entered: 10/08/2004)

ORDER denying 4 Motion to Dismiss . Defendant's motion to dismiss the Complaint is denied. (Signed by Judge Laura Taylor Swain on 11/4/04) (jco, ) (Entered: 11/08/2004)

MOTION to Continue Initial Pre-trial Conference. Document filed by Equal Employment Opportunity Commission. (Santos, Adela) (Entered: 11/10/2004)

ENDORSED LETTER addressed to Judge Swain from Adela P. Santos dated 11/10/04 re: counsel requests an adjournment of pre-trial conference; the conference is adjourned to December 17, 2004; (Signed by Judge Laura Taylor Swain on 11/11/04) (djc, ) (Entered: 11/15/2004)

Set Deadlines/Hearings: Pretrial Conference set for 12/17/2004 02:00 PM before Judge Laura Taylor Swain. (djc, ) (Entered: 11/15/2004)

Set Deadlines/Hearings: Pretrial Conference set for 12/17/2004 02:00 PM before Judge Laura Taylor Swain. (djc, )

JOINT MOTION for Extension of Time by Letter to the Honorable Laura Taylor Swain, U.S.D.J.. Document filed by Teamsters Local 804. (Brook, Richard) (Entered: 12/13/2004)

CERTIFICATE OF SERVICE of Memo Endorsement on the December 13, 2004 letter from Richard Brook to the Court served on Katherine E. Bissell, Elizabeth Grossman and Adela P. Santos on December 14, 2004. Service was made by FAX. Document filed by Teamsters Local 804. (Brook, Richard) (Entered: 12/14/2004)

ENDORSED LETTER addressed to Judge Swain from Richard Brook dated 12/13/04 re: parties requests that the court adjourn the conference scheduled for Deccember 17, 2004 and all related deadlines to the second week in January 2005; the conference is adjourned to January 28, 205 at 2:00 p.m. and the related deadlines are modified accordingly; (Signed by Judge Laura Taylor Swain on 12/13/04) (djc, ) (Entered: 12/14/2004)

ANSWER to Complaint. Document filed by Teamsters Local 804.(Brook, Richard) (Entered: 01/18/2005)

PRELIMINARY PRETRIAL STATEMENT. Document filed by Equal Employment Opportunity Commission.(Santos, Adela) (Entered: 01/25/2005)

Minute Entry for proceedings held before Judge Laura Taylor Swain : Interim Pretrial Conference held on 1/28/2005. Parties referred to MJ for GPT - PTC adj to 1/5/06 at 2:15 p.m. - orders signed. (kw, ) (Entered: 02/17/2005)

Minute Entry for proceedings held before Judge Laura Taylor Swain : Interim Pretrial Conference held on 1/28/2005. Parties referred to MJ for GPT - PTC adj to 1/5/06 at 2:15 p.m. - orders signed. (kw, )

SCHEDULING ORDER: Amended Pleadings due by 3/18/2005. all expert witness Discovery due by 8/30/2005. Pretrial Conference set for 1/5/2006 02:15 PM before Judge Laura Taylor Swain. (Signed by Judge Laura Taylor Swain on 1/28/05; copies given to counsel of record (djc, ) (Entered: 02/01/2005)

ORDER REFERRING CASE TO MAGISTRATE JUDGE. Order that case be referred to the Clerk of Court for assignment to a Magistrate Judge for general pretrial (includes scheduling, discovery, non-dispositive pretrial motions, and settlement). Referred to Magistrate Judge Frank Maas. (Signed by Judge Laura Taylor Swain on 1/28/05) (djc, ) (Entered: 02/01/2005)

RULE 26 DISCLOSURE.Document filed by Equal Employment Opportunity Commission.(Santos, Adela) (Entered: 02/07/2005)

Minute Entry for proceedings held before Judge Frank Maas : Settlement Conference held on 3/2/2005. settlement conf. held before Mag. Judge Maas; parties are unable to reach a settlement. (dle, ) (Entered: 03/18/2005)

Minute Entry for proceedings held before Judge Frank Maas : Settlement Conference held on 3/2/2005. settlement conf. held before Mag. Judge Maas; parties are unable to reach a settlement. (dle, )

ORDER; Purs to the settlement conf held on 03/22/05, it is hereby Ordered that a telephone conf in this matter shall be held on 03/24/05 at 10:00 a.m.... (Signed by Judge Frank Maas on 3/3/05) (djc, ) (Entered: 03/08/2005)

Set Deadlines/Hearings: Telephone Conference set for 3/24/2005 10:00 AM before Magistrate Judge Frank Maas. (djc, ) (Entered: 03/08/2005)

Set Deadlines/Hearings: Telephone Conference set for 3/24/2005 10:00 AM before Magistrate Judge Frank Maas. (djc, )

AMENDED ANSWER to 1 Complaint. Document filed by Teamsters Local 804. (Brook, Richard) (Entered: 03/18/2005)

ENDORSED LETTER addressed to Magistrate Judge Frank Maas from Richard Brook dated 3/23/05; re: conference adjourned to 4/1/05 at 3 p.m.. (Signed by Judge Frank Maas on 3/25/05) (sac, ) (Entered: 04/01/2005)

ORDER. Pursuant to today's telephone conference, it is hereby ordered that a further telephone conference in this matter shall be held on 8/15/2005 at 10:00 AM for the plaintiff shall initiate the call (Signed by Judge Frank Maas on 4/1/05) Copies sent by Chambers (yv, ) Modified on 4/5/2005 (yv, ). (Entered: 04/05/2005)

Minute Entry for proceedings held before Judge Frank Maas : Telephone Conference held on 8/15/2005. Discovery issues addressed. (db, ) (Entered: 08/17/2005)

Minute Entry for proceedings held before Judge Frank Maas : Telephone Conference held on 8/15/2005. Discovery issues addressed. (db, )

FILING ERROR - ELECTRONIC FILING FOR NON-ECF DOCUMENT - MOTION for Extension of Time to Complete Discovery. Document filed by Equal Employment Opportunity Commission (Letter). (Attachments: # 1)(Santos, Adela) Modified on 9/13/2005 (kg). (Entered: 08/16/2005)

ENDORSED LETTER addressed to Judge Maas from Adela Santos dated 8/16/05 re: request for an extension of the discovery deadline. Judge Swain's final pretrial conference is adjourned to 2/24/2006 at 02:00 PM, which enables the parties to extend all interim dates 6 weeks. Counsel should submit an agreed revised schedule within 10 days (Signed by Judge Frank Maas on 8/28/05) (yv, ) (Entered: 09/01/2005)

FILING ERROR - ELECTRONIC FILING FOR NON-ECF DOCUMENT - MOTION to Approve Agreed Revised Schedule (Letter). Document filed by Equal Employment Opportunity Commission. (Attachments: # 1)(Santos, Adela) Modified on 9/13/2005 (kg). (Entered: 09/09/2005)

***NOTE TO ATTORNEY TO RE-FILE DOCUMENT - NON-ECF DOCUMENT ERROR. Note to Attorney Adela Santos to MANUALLY RE-FILE Document No. 31 Letter. This document is not filed via ECF. (kg) (Entered: 09/13/2005)

***NOTE TO ATTORNEY TO RE-FILE DOCUMENT - NON-ECF DOCUMENT ERROR. Note to Attorney Adela Santos to MANUALLY RE-FILE Document No. 31 Letter. This document is not filed via ECF. (kg)

ENDORSED LETTER addressed to Magistrate Judge Frank Maas from Adela Santos dated 9/9/05 re: Application GRANTED. The interim dates proposed shall govern the remaining pre-trial proceedings in this case. Additionally, the Court will hold a telephone conference, to be initiated by the EEOC, on 11/15/05 at 5:00 p.m. Dispositive pre-trial motions due 11/15/05; Joint Pre-trial Statement; all other deadlines as further set forth in said order. (Signed by Judge Frank Maas on 9/20/05) (db, ) Modified on 9/22/2005 (gf, ). (Entered: 09/22/2005)

Set Deadlines/Hearings: Dospositive Pre-Trial Motions due by 11/15/2005. Joint-Pretrial Statement due by 2/14/2006. Telephone Conference set for 11/15/2005 05:00 PM before Magistrate Judge Frank Maas. (db, ) (Entered: 09/22/2005)

Set Deadlines/Hearings: Dospositive Pre-Trial Motions due by 11/15/2005. Joint-Pretrial Statement due by 2/14/2006. Telephone Conference set for 11/15/2005 05:00 PM before Magistrate Judge Frank Maas. (db, )

FILING ERROR - ELECTRONIC FILING FOR NON-ECF DOCUMENT - MOTION for Extension of Time to Complete Discovery (Letter). Document filed by Equal Employment Opportunity Commission. (Santos, Adela) Modified on 10/19/2005 (kg). (Entered: 10/12/2005)

RESPONSE to Motion re: 33 MOTION for Extension of Time to Complete Discovery.. Document filed by Teamsters Local 804. (Brook, Richard) (Entered: 10/14/2005)

ENDORSED LETTER addressed to Judge Maas from Richard Brook dated 10/14/05: the Court will hold a telephone conf on 10/27/05 at 10 am, with Mr. Brook to intiate the call. (Signed by Judge Frank Maas on 10/17/05) (cd, ) (Entered: 10/18/2005)

ENDORSED LETTER addressed to Judge Maas from Adela Santos dated 10/12/05: fact discovery is extended through 11/18/05. (Signed by Judge Frank Maas on 10/14/05) (cd, ) (Entered: 10/18/2005)

Set/Reset Hearings: Telephone Conference set for 10/27/2005 10:00 AM before Magistrate Judge Frank Maas. (cd, ). (Entered: 10/18/2005)

Set/Reset Hearings: Telephone Conference set for 10/27/2005 10:00 AM before Magistrate Judge Frank Maas. (cd, ).

Minute Entry for proceedings held before Judge Frank Maas : Telephone Conference held on 11/1/2005. Discovery issues addressed. (pl, ) (Entered: 11/04/2005)

Minute Entry for proceedings held before Judge Frank Maas : Telephone Conference held on 11/1/2005. Discovery issues addressed. (pl, )

ORDER that plntf shall produce to the court for in camera review any allegedly privileged documents, as further set forth in this document. The telephone conf set for 11/5 is cancelled. (Signed by Judge Frank Maas on 11/2/05) copie sent by chambers(cd, ) (Entered: 11/07/2005)

ORDER; on or before 11/8/05 pltf shall produce to the Court for in camera review any allegedly privileged documents. Defendant shall submit a response by 11/10/2005. Deft's application for leave to depose the pltf investigator is granted. Deft's application to limit the scope of remaining discovery is denied. Counsel shall agree on a revised schedule to govern pretrial proceedings, and submit it to the Court for approval. The telephone conference previously scheduled for 11/15/05 at 5 p.m. is cancelled. (Signed by Judge Frank Maas on 11/2/05) (kco, ) (Entered: 11/08/2005)

AFFIDAVIT OF SERVICE of Affidavit of Adela Santos in Support of Plaintiff EEOC's Objection to Disclosure of Documents Withheld Under a Claim of Privilege served on Teamsters Local 804 on 11/08/2005. Service was made by Fax. Document filed by Equal Employment Opportunity Commission. (Santos, Adela) (Entered: 11/09/2005)

RESPONSE re: 39 Affidavit of Service Other, re: in camera review of documents. Document filed by Teamsters Local 804. (Brook, Richard) (Entered: 11/10/2005)

ENDORSED LETTER addressed to Judge Maas from Richard Brook dated 11/18/05 re aggred revised scheduling order: completionof discovery 11/18/05; dispositive pretrial motions 1/13/06; preliminary conf between counsel 3/8/06; other evidentiary pre trial motions 3/22/06; joint pre trial statement 4/4/06; final ptc 4/28/06. (Signed by Judge Frank Maas on 11/22/05) (cd, ) (Entered: 11/23/2005)

ENDORSED LETTER addressed to Magistrate Judge Frank Maas from Adela Santos dated 11/8/05 re: as the decision attached to Ms. Santos' affidavit confirms, the deliberate process privilege protects from disclosure documents which the agency head determines should be withheld. Here, there is no indication that anybody above the level of a trial attorney was involved. Accordingly, the privilege cannot be invoked by the EEOC. Exhibits A and C through F therefore must be disclosed. I note that exhibits C through F are forms which are entirely innocuous. Exhibit A, on the other hand, is an investigative menu which summarizes the facts and makes a recommendation. The EEOC may withhold the recommendation section of exhibit A on work-product grounds. The EEOC is directed to make this redaction and produce the documents within three business days. (Signed by Judge Frank Maas on 11/28/05) (db, ) (Entered: 11/28/2005)

AFFIDAVIT OF SERVICE of Letter dated December 1, 2005 to Hon. Frank Maas served on Teamsters Local 804 on December 1, 2005. Service was made by Fax. Document filed by Equal Employment Opportunity Commission. (Santos, Adela) (Entered: 12/01/2005)

ENDORSED LETTER addressed to Mag. Judge Frank Maas from Adela Santos dated 12/1/05 re: a motion for reconsideration would be futile since there is no matter I overlooked in ruling. See Local Civil Rule 6.3. Accordingly, the application is denied. (Signed by Judge Frank Maas on 12/2/05) (pl, ) (Entered: 12/05/2005)

FILING ERROR - ELECTRONIC FILING FOR NON-ECF DOCUMENT - MOTION to Set Aside or modify November 28, 2005 Order issued by the Hon. Magistrate Judge Frank Maas (LETTER). Document filed by Equal Employment Opportunity Commission. (Attachments: # 1 # 2 # 3 # 4 # 5 # 6 # 7 # 8)(Santos, Adela) Modified on 12/15/2005 (kg). (Entered: 12/06/2005)

RESPONSE in Opposition re: 45 MOTION to Set Aside or modify November 28, 2005 Order issued by the Hon. Magistrate Judge Frank Maas.. Document filed by Teamsters Local 804. (Brook, Richard) (Entered: 12/13/2005)

***NOTE TO ATTORNEY TO RE-FILE DOCUMENT - NON-ECF DOCUMENT ERROR. Note to Attorney Adela Santos to MANUALLY RE-FILE Document No. 45 Letter. This document is not filed via ECF. (kg) (Entered: 12/15/2005)

***NOTE TO ATTORNEY TO RE-FILE DOCUMENT - NON-ECF DOCUMENT ERROR. Note to Attorney Adela Santos to MANUALLY RE-FILE Document No. 45 Letter. This document is not filed via ECF. (kg)

LETTER addressed to Judge Laura Taylor Swain from Adela Santos dated 12/6/05 re: requests that your Honor set aside or modify a 11/28/05 order issued by the Honorable Mag. Judge Frank Maas; w/ Exhibits. Document filed by Equal Employment Opportunity Commission.(pl, ) (Entered: 01/09/2006)

ORDER that the Court finds no basis to disturb Judge Maas' findings with regard to production of the relevant documents. Plntf's motion is therefore denied in its entirety. (Signed by Judge Laura Taylor Swain on 1/6/06) copies sent by chambers.(cd, ) (Entered: 01/09/2006)

NOTICE OF CASE REASSIGNMENT to Judge Paul A. Crotty. Judge Laura Taylor Swain no longer assigned to the case. (jeh, ) Modified on 1/20/2006 (jeh, ). (Entered: 01/20/2006)

MOTION for Summary Judgment and Notice of Motion. Document filed by Teamsters Local 804. (Attachments: # 1 Affidavit of Service# 2 Statement Explaining "Delayed" Filing)(Brook, Richard) (Entered: 01/20/2006)

DECLARATION of Anthony Magrene in Support re: 50 MOTION for Summary Judgment and Notice of Motion.. Document filed by Teamsters Local 804. (Brook, Richard) (Entered: 01/20/2006)

DECLARATION of Richard A. Brook in Support re: 50 MOTION for Summary Judgment and Notice of Motion.. Document filed by Teamsters Local 804. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C part 1# 4 Exhibit C part 2# 5 Exhibit D# 6 Exhibit E# 7 Exhibit F# 8 Exhibit G# 9 Exhibit H# 10 Exhibit I# 11 Exhibit J# 12 Exhibit K# 13 Exhibit L# 14 Exhibit M# 15 Exhibit N# 16 Exhibit O)(Brook, Richard) (Entered: 01/20/2006)

RULE 56.1 STATEMENT. Document filed by Teamsters Local 804. (Brook, Richard) (Entered: 01/20/2006)

MEMORANDUM OF LAW in Support re: 50 MOTION for Summary Judgment and Notice of Motion.. Document filed by Teamsters Local 804. (Attachments: # 1 Addendum - Table of Contents# 2 Addendum 1# 3 Addendum 2)(Brook, Richard) (Entered: 01/20/2006)

ENDORSED LETTER: addressed to Judge Paul A. Crotty from Adela P. Santos dated 1/31/06. ENDORSEMENT: EEOC's response is due on 2/7/06. Defendants reply is due on 2/16/06. So Ordered. (Signed by Judge Paul A. Crotty on 2/1/06) (js, ) (Entered: 02/01/2006)

ENDORSED LETTER addressed to Judge Crotty from Adela P. Santos dated 02/08/2006 re: Request to file response to defnedant's motion for summary judgment by the close of business of today.ENDORSEMENT: Permission is granted. So Ordered. (Signed by Judge Paul A. Crotty on 02/08/2006) (mov, ) (Entered: 02/08/2006)

FILING ERROR - DEFICIENT DOCKET ENTRY - DECLARATION of Adela Santos in Opposition re: 50 MOTION for Summary Judgment and Notice of Motion.. Document filed by Equal Employment Opportunity Commission. (Santos, Adela) Modified on 2/16/2006 (gf, ). (Entered: 02/08/2006)

RESPONSE in Opposition re: 50 MOTION for Summary Judgment and Notice of Motion.. Document filed by Equal Employment Opportunity Commission. (Santos, Adela) (Entered: 02/08/2006)

MEMORANDUM OF LAW in Opposition re: 50 MOTION for Summary Judgment and Notice of Motion.. Document filed by Equal Employment Opportunity Commission. (Santos, Adela) (Entered: 02/08/2006)

DECLARATION of Adela Santos in Opposition re: 50 MOTION for Summary Judgment and Notice of Motion.. Document filed by Equal Employment Opportunity Commission. (Attachments: # 1 # 2)(Santos, Adela) (Entered: 02/09/2006)

ENDORSED LETTER addressed to Judge Paul A. Crotty from Richard A. Brook dated 2/10/06 re: Counsel for defendant writes to request that the Court reset the due date for Local 804's reply to 2/17/06 in light of the one-day extension granted to plaintiff EEOC. The time for Local 804 reply is adjourned to 2/17/06. So Ordered. (Signed by Judge Paul A. Crotty on 2/14/06) (jco, ) (Entered: 02/14/2006)

DECLARATION of Anthony Magrene (Supplemental) in Support re: 50 MOTION for Summary Judgment and Notice of Motion.. Document filed by Teamsters Local 804. (Brook, Richard) (Entered: 02/17/2006)

DECLARATION of Richard A. Brook (Supplemental) in Support re: 50 MOTION for Summary Judgment and Notice of Motion.. Document filed by Teamsters Local 804. (Attachments: # 1 Exhibit P# 2 Exhibit Q# 3 Exhibit R# 4 Exhibit S# 5 Exhibit T# 6 Exhibit U# 7 Exhibit V)(Brook, Richard) (Entered: 02/17/2006)

REPLY MEMORANDUM OF LAW in Support re: 50 MOTION for Summary Judgment and Notice of Motion.. Document filed by Teamsters Local 804. (Brook, Richard) (Entered: 02/17/2006)

ENDORSED LETTER addressed to Judge Paul A. Crotty from Adela Sanros dated 2/23/06 re: the EEOC's request to file a sur on reply is DENIED. (Signed by Judge Paul A. Crotty on 2/27/06) (db, ) (Entered: 02/27/2006)

ENDORSED LETTER addressed to Judge Paul A. Crotty from Richard A. Brook dated 3/9/06. ENDORSEMENT: The proposed revised scheduling order is adopted. The final pretrial conference will be scheduled in May 2006 by my Courtroom Deputy. (Signed by Judge Paul A. Crotty on 3/13/06) (kco, ) (Entered: 03/13/2006)

Minute Entry for proceedings held before Judge Paul A. Crotty : Remark: Oral Argument heard on Defendant's Motion for Summary Judgment. Judge's Decision is reserved (see transcript - court reporter: Joanne Mancari). Oral Argument held on 4/7/2006 re: 50 MOTION for Summary Judgment and Notice of Motion . filed by Teamsters Local 804,. (mov, ) (Entered: 04/08/2006)

Minute Entry for proceedings held before Judge Paul A. Crotty : Remark: Oral Argument heard on Defendant's Motion for Summary Judgment. Judge's Decision is reserved (see transcript - court reporter: Joanne Mancari). Oral Argument held on 4/7/2006 re: 50 MOTION for Summary Judgment and Notice of Motion. filed by Teamsters Local 804,. (mov, )

MEMORANDUM ORDER: denying 50 Motion for Summary Judgment. The Court finds that Local 804 had eighteen employees, which subjects Local 804 to a total potential compensatory and punitive damages liability of $50,000. 42 USC 1981(b)(3). In light of the limited monetary exposure and the complex questions that must be resolved on this imperfect record, the Court encourages the parties to engage in good faith negotiations to resolve their differences... (Signed by Judge Paul A. Crotty on 4/12/2006) (lb, ) (Entered: 04/12/2006)

TRANSCRIPT of proceedings held on 4/7/2006 before Judge Paul A. Crotty. (jar, ) (Entered: 04/20/2006)