Case: Richards v. Convergys

EEOC v. Convergys

Richards v. Convergys Corp.

Richards v. Convergys Corporation

Richards v. Convergys Corporation

Richards v. EEOC v. Convergys Corporation

Richards v. Convergys Corporation& EEOC v. Convergeys Corporation

Carly Knight, Frank Dobbin, Alexandra Kalev

COMPLAINT against Convergys (Filing fee $ 250, receipt number 4681006481), filed by Jennifer Richards.Assigned to Judge Dale A. Kimball (rlr, ) (Entered: 09/22/2005)

STIPULATION/MOTION for Extension of Time to File Answer BY 11/21/05 re 1 Complaint filed by Defendant Convergys. (blk, ) (Entered: 11/01/2005)

ORDER granting 2 Motion for Extension of Time to Answer re 1 Complaint. Answer deadline updated for Convergys answer due 11/21/2005. . Signed by Judge Dale A. Kimball on 10/31/05. (blk, ) (Entered: 11/03/2005)

ANSWER to Complaint filed by Convergys.(Levin, Ali) (Entered: 11/21/2005)

NOTICE OF ADR, e-mailed or mailed to Plaintiff Jennifer Richards, Defendant Convergys. (blk, ) (Entered: 11/28/2005)

Cases associated with lead consolidated case 2:05cv790. (blk, ) (Entered: 12/05/2005)

ORDER CONSOLIDATING CASES. Case 2:05cv812 is consolidated into this lead case. This case (2:05cv790) will be the lead case and is the only one that will be docketed in per the entry of this order.. Signed by Judge Dale A. Kimball on 12/2/05. (blk, ) (Entered: 12/05/2005)

Defendant's ANSWER to Complaint filed by EEOC filed by Convergys.(O'Brien, Michael) (Entered: 12/12/2005)

NOTICE OF INITIAL PRETRIAL CONFERENCE: (Notice generated by clerk)***The Attorneys Planning Meeting Report and Proposed Scheduling Order forms, available on the court web site at http://www.utd.uscourts.gov/documents/formpage.html, should be prepared 30 days before the Initial Pretrial Conference hearing date. The Court may enter a scheduling order and vacate the hearing if counsel (a) file a stipulated Attorneys Planning Meeting Report and (b) e-mail a Proposed Scheduling Order to ipt@utd.uscourts.gov 30 days before the scheduled hearing.*** Initial Pretrial Conference set for 1/25/2006 01:30 PM in Room 477 before Magistrate Judge David Nuffer. (blk, ) (Entered: 12/13/2005)

MOTION/ORDER granting motion for Admission Pro Hac Vice for of Catherine Ann Reed for Jennifer Richards.Attorneys admitted pro hac vice may download a copy of the District of Utah's local rules from court's web site at http://www.utd.uscourts.gov. Signed by Judge Dale A. Kimball on 12/21/05. (blk, ) (Entered: 12/22/2005)

Modification of Docket: Error: Added Catherine Ann Reed as counsel for plaintiff. Correction: Termed Ms. Reed as counsel for plaintiff and added her as counsel for dft Convergys Corporation. re 9 Motion/Order Pro Hac Vice,. (blk, ) (Entered: 12/22/2005)

MOTION/ORDER granting motion for Admission Pro Hac Vice for of David A. Skidmore for Convergys.Attorneys admitted pro hac vice may download a copy of the District of Utah's local rules from court's web site at http://www.utd.uscourts.gov. Signed by Judge Dale A. Kimball on 12/21/05. (blk, ) (Entered: 12/22/2005)

REPORT OF ATTORNEY PLANNING MEETING. (Reed, Catherine) (Entered: 01/09/2006)

NOTICE REMINDER of Attorneys' Planning Meeting Report due five days from receipt of this notice re 8 NOTICE OF INITIAL PRETRIAL CONFERENCE: (Notice generated by clerk)***The Attorneys Planning Meeting Report and Proposed Scheduling Order forms, available on the court web site at http://www.utd.uscourts.gov/documents/formpage.html, should be prepared 30 days before the Initial Pretrial Conference hearing date. The Court may enter a scheduling order and vacate the hearing if counsel (a) file a stipulated Attorneys Planning Meeting Report and (b) e-mail a Proposed Scheduling Order to ipt@utd.uscourts.gov 30 days before the scheduled hearing.*** Initial Pretrial Conference set for 1/25/2006 01:30 PM in Room 477 before Magistrate Judge David Nuffer. (blk, ) (tsh, ) (Entered: 01/12/2006)

SCHEDULING ORDER: Initial Pretrial Conference set for 1/25/06 vacated. Amended Pleadings due by 2/15/2006. Joinder of Parties due by 2/15/2006. Discovery due by 9/15/2006. Motions due by 10/31/2006. Final Pretrial Conference set for 3/26/2007 02:30 PM in Room 220 before Judge Dale A. Kimball. 7 day Jury Trial set for 4/9/2007 08:30 AM in Room 220 before Judge Dale A. Kimball.. Signed by Judge David Nuffer on 1/11/06. (blk, ) (Entered: 01/12/2006)

CERTIFICATE of Counsel for Service of Initial Rule 26(a)(1) Disclosure Statement by Sandra J. Padegimas for Consol Plaintiff Equal Employment Opportunity Commission (Padegimas, Sandra) (Entered: 01/26/2006)

CERTIFICATE of Counsel of Service of Defendant Convergys' Rule 26 Disclosures by Catherine Ann Reed for Defendant Convergys (Reed, Catherine) (Entered: 02/14/2006)

Joint MOTION for Scheduling Order Regarding Trial Date and Final Pretrial Conference filed by Defendant Convergys. (Levin, Ali) (Entered: 02/14/2006)

NOTICE OF HEARING: (Notice generated by Kim Jones)7-day Jury Trial reset for 4/30/2007 08:30 AM in Room 220 before Judge Dale A. Kimball. Final Pretrial Conference reset for 4/16/2007 02:30 PM before Judge Dale A. Kimball. (kmj, ) (Entered: 02/16/2006)

ORDER granting 17 Motion for Scheduling Order. Final Pretrial Conference reset for 4/16/2007 02:30 PM in Room 220 before Judge Dale A. Kimball. 7 day Jury Trial reset for 4/30/2007 08:30 AM in Room 220 before Judge Dale A. Kimball. Signed by Judge Dale A. Kimball on 2/16/06. (kmj, ) (Entered: 02/16/2006)

CERTIFICATE OF SERVICE by Equal Employment Opportunity Commission for First Set of Interrogatories and Request for Production of Documents to Defendant (Padegimas, Sandra) (Entered: 03/07/2006)

NOTICE OF FILING Certificate of Service of Defendant's First Set of Interrogatories and First Request for Production of Documents Addressed to Plaintiff Equal Employment Opportunity Commission filed by Defendant Convergys. (Reed, Catherine) (Entered: 03/16/2006)

CERTIFICATE OF SERVICE re: discovery by Jennifer Richards (blk, ) (Entered: 03/22/2006)

MOTION to Withdraw as Attorney for Plaintiff EEOC filed by Consol Plaintiff Equal Employment Opportunity Commission. (Attachments: # 1 Text of Proposed Order)(Smith, C.) (Entered: 03/28/2006)

2 Text of Proposed Order

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MOTION/ORDER granting motion for Admission Pro Hac Vice for of Sally C. Shanley for Equal Employment Opportunity Commission.Attorneys admitted pro hac vice may download a copy of the District of Utah's local rules from court's web site at http://www.utd.uscourts.gov. Signed by Judge Dale A. Kimball on 3/31/06. (blk, ) (Entered: 03/31/2006)

ORDER granting 23 Motion to Withdraw as Attorney. Attorney C. Emmanuel Smith withdrawn from case . Signed by Judge Dale A. Kimball on 4/3/06. (blk, ) (Entered: 04/05/2006)

CERTIFICATE OF SERVICE by Jennifer Richards of Plaintiff's First Set of Written Discovery to Defendant (Chamness, Ralph) (Entered: 04/07/2006)

CERTIFICATE OF SERVICE by Equal Employment Opportunity Commission of Response to Defendant's Discovery Requests (Padegimas, Sandra) (Entered: 04/25/2006)

CERTIFICATE OF SERVICE by Convergys of Defendant's Discovery Requests (Reed, Catherine) (Entered: 05/08/2006)

CERTIFICATE OF SERVICE by Jennifer Richards re 28 Certificate of Service PLAINTIFF'S ANSWERS TO FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS (Chamness, Ralph) (Entered: 06/07/2006)

THIS DOCUMENT SHOULD BE FILED IN A DIFFERENT CASE - MOTION for Protective Order Stipulated Protectived Order filed by Defendant Convergys. (Attachments: # 1)(O'Brien, Michael) Modified on 6/8/2006: text added per Notice of Deficiency #31 (alt) (Entered: 06/07/2006)

NOTICE OF DEFICIENCY re: 30 MOTION for Protective Order Stipulated Protectived Order. The document is filed in the wrong case and the attachment is not identified. The court asks the filer of the original document to refile the pleading in the correct case and to identify the attachment (alt) (Entered: 06/08/2006)

Defendant's MOTION for Protective Order filed by Defendant Convergys. (Attachments: # 1 Text of Proposed Order Stipulated Protective Order)(O'Brien, Michael) (Entered: 06/08/2006)

2 Text of Proposed Order Stipulated Protective Order

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ORDER granting 32 Stipulated Motion for Protective Order . Signed by Judge Dale A. Kimball on 6/19/06. (awm ) (Entered: 06/19/2006)

Minute Entry for proceedings held before Judge David Nuffer : Discovery Hearing held on 7/7/2006. Counsel present via telephone conference. Discussion heard on the discovery and deposition dispute of Ms. Jennifer Richards. The deposition is currently scheduled to commence on 7/10/06. Discussion heard on the possibility of rescheduling Ms. Richard's deposition from 7/10/06 to 7/21/06. Court ordered that the deposition be rescheduled for 7/21/06 and that Convergys to provide supplemental responses to discovery on or before 7/17/06 (delivery date). Court adjourned.Attorneys for Plaintiff: Sandy Padegimas, Ralph Chamness, Attorneys for Defendant David Skidmore, Catherine Reed, Michael O'Brien.(Court Reporter Electronic, Tape #418, Log #51-1198, Room 477.) (asb, ) (Entered: 07/07/2006)

CERTIFICATE OF SERVICE by Equal Employment Opportunity Commission for First Supplemental Disclosure Statement (Padegimas, Sandra) (Entered: 07/12/2006)

CERTIFICATE OF SERVICE by Equal Employment Opportunity Commission for Second Supplemental Disclosure and Second Discovery Requests (Padegimas, Sandra) (Entered: 07/12/2006)

MOTION to Compel discovery responses filed by Consol Plaintiff Equal Employment Opportunity Commission. (Attachments: # 1 # 2 # 3 # 4 # 5 # 6 # 7 # 8 # 9)(Nutter, Karen) (Entered: 07/19/2006)

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CERTIFICATE OF SERVICE by Equal Employment Opportunity Commission for Third Supplemental Disclosures and Third Discovery Requests (Shanley, Sally) (Entered: 07/24/2006)

ORDER REFERRING CASE to Magistrate Judge David Nuffer under 28:636 (b)(1)(A), Magistrate to hear and determine all nondispositive pretrial matters.. Signed by Judge Dale A. Kimball on 07/26/06. (abr, ) (Entered: 07/26/2006)

SUBSTITUTION OF COUNSEL April L. Hollingsworth replacing Ralph E. Chamness as counsel on behalf of Jennifer Richards. (Hollingsworth, April) (Entered: 08/03/2006)

MEMORANDUM in Opposition re 37 MOTION to Compel discovery responses and for Protective Order filed by Defendant Convergys. (Reed, Catherine) (Entered: 08/04/2006)

CERTIFICATE OF SERVICE by Convergys of Defendant's Answers to Plaintiff EEOC's Second Set of Interrogatories and Defendant's Responses to Plaintiff EEOC's Second Request for Production of Documents (Reed, Catherine) (Entered: 08/09/2006)

Plaintiff's MOTION for Extension of Time to Complete Discovery filed by Plaintiff Jennifer Richards. (Hollingsworth, April) (Entered: 08/11/2006)

Plaintiff's MEMORANDUM in Support re 43 Plaintiff's MOTION for Extension of Time to Complete Discovery filed by Plaintiff Jennifer Richards. (Attachments: # 1 Text of Proposed Order)(Hollingsworth, April) (Entered: 08/11/2006)

2 Text of Proposed Order

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DOCKET TEXT ORDER taking under advisement 43 Motion for Extension of Time to Complete Discovery.IT IS HEREBY ORDERED that any response to this motion shall be filed on or before August 23, 2006, and any reply shall be filed within 2 business days of the response. Any document filed shall address implications for the trial date in the case in light of the policy that "five months must be allowed between the dispositive motion deadline and the trial date to allow the motions to be filed, briefed, set, argued and decided before trial preparation starts." http://www.utd.uscourts.gov/documents/ipt.html.Any document filed shall be simultaneously emailed to opposing counsel and mj.nuffer@utd.uscourts.gov, in addition to other service. Signed by Judge David Nuffer on August 14, 2006.No attached document. (Nuffer, David) (Entered: 08/14/2006)

ORDER granting 43 Motion for Extension of Time to Complete Discovery. Discovery due: 12/15/06. Signed by Judge Dale A. Kimball on 8/17/06.(blk, ) (Entered: 08/17/2006)

DOCKET TEXT ORDER: The Order 46 granting Plaintiff's Motion for Extension of Time to Complete Discovery 43 was entered in error and is hereby VACATED. The parties should proceed according to the Docket Text Order entered by Magistrate Judge Nuffer on 8/14/06. Signed by Judge Dale A. Kimball on 8/17/06. (awm, ) (Entered: 08/17/2006)

REPLY to Response to Motion re 37 MOTION to Compel discovery responses filed by Consol Plaintiff Equal Employment Opportunity Commission. (Attachments: # 1 Exhibits A - C)(Padegimas, Sandra) (Entered: 08/18/2006)

2 Exhibits A - C

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Defendant's MEMORANDUM in Opposition re 43 Plaintiff's MOTION for Extension of Time to Complete Discovery filed by Defendant Convergys. (Attachments: # 1 Exhibit A)(Skidmore, David) (Entered: 08/23/2006)

2 Exhibit A

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REPLY to Response to Motion re 43 Plaintiff's MOTION for Extension of Time to Complete Discovery filed by Plaintiff Jennifer Richards. (Attachments: # 1 Exhibit A; Declaration of Sandra Padegimas)(Hollingsworth, April) (Entered: 08/25/2006)

2 Exhibit A; Declaration of Sandra Padegimas

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ERRATA to 37 MOTION to Compel discovery responses filed by Consol Plaintiff Equal Employment Opportunity Commission. (Attachments: # 1 Exhibit E)(Shanley, Sally) (Entered: 08/29/2006)

2 Exhibit E

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MEMORANDUM DECISION & ORDER granting in part 37 Motion to Compel, granting in part 43 Motion for Extension of Time to Complete Discovery . Signed by Judge David Nuffer on 9/5/06.(blk, ) (Entered: 09/05/2006)

CERTIFICATE OF SERVICE by Equal Employment Opportunity Commission First Supplemental Responses to Defendant's First Request for Documents (Padegimas, Sandra) (Entered: 09/13/2006)

CERTIFICATE OF SERVICE by Convergys of Defendant's First Requests for Admission and Second Set of Interrogatories to Plaintiff Equal Employment Opportunity Commission (Reed, Catherine) (Entered: 09/19/2006)

CERTIFICATE OF SERVICE by Convergys of Defendant's First Requests for Admission and Second Set of Interrogatories to Plaintiff Jennifer Richards (Reed, Catherine) (Entered: 09/19/2006)

CERTIFICATE OF SERVICE by Convergys of Defendant's Supplemental Responses to Plaintiff Equal Employment Opportunity Commission's First Request for Production of Documents and Interrogatories (Reed, Catherine) (Entered: 09/20/2006)

CERTIFICATE OF SERVICE by Jennifer Richards Answers to Requests for Admission and Second Set of Interrogatories (Hollingsworth, April) (Entered: 10/17/2006)

CERTIFICATE OF SERVICE by Convergys of Defendant's Supplemental Responses to Plaintiff Equal Employment Opportunity Commission's Discovery Requests (Reed, Catherine) (Entered: 10/17/2006)

CERTIFICATE OF SERVICE by Equal Employment Opportunity Commission for Responses to Defendant's Discovery Requests (Padegimas, Sandra) (Entered: 10/19/2006)

CERTIFICATE OF SERVICE by Jennifer Richards Second Set of Discovery (Hollingsworth, April) (Entered: 10/19/2006)

CERTIFICATE OF SERVICE by Convergys of Its Revised Rule 26 Disclosures (Reed, Catherine) (Entered: 11/06/2006)

MOTION for Admission Pro Hac Vice of Mekesha Houchins Montgomery Registration fee $ 15, receipt number 414768. filed by Defendant Convergys. (Attachments: # 1)(O'Brien, Michael) (Entered: 11/07/2006)

ORDER granting 62 Motion for Admission Pro Hac Vice of Mekesha Houchins Montgomery for Convergys. Attorneys admitted Pro Hac Vice may download a copy of the District of Utahs local rules from the courts web site at http://www.utd.uscourts.gov . Signed by Judge Dale A. Kimball on 11/8/06.(blk, ) (Entered: 11/08/2006)

**RESTRICTED DOCUMENT** RETURN OF SERVICE Executed for Subpoena and Subpoena Duces Tecum served on Colleen Maughan on November 10, 2006, filed by Defendant Convergys. (O'Brien, Michael) (Entered: 11/16/2006)

CERTIFICATE OF SERVICE by Convergys Second Supplemental Discovery Responses (Skidmore, David) (Entered: 11/17/2006)

**RESTRICTED DOCUMENT** RETURN OF SERVICE Executed for Subpoena and Subpoena Duces Tecum served on Michelle Renea Montague on November 14, 2006, filed by Defendant Convergys. (O'Brien, Michael) (Entered: 11/17/2006)

MOTION to Compel discovery filed by Defendant Convergys. (Attachments: # 1 Exhibit A--Proposed Order# 2 Exhibit B--EEOC's Initial Rule 26(a)(1) Disclosure Statement# 3 Exhibit C--Richards' Initial Disclosures# 4 Exhibit D--9/22/06 Hollingsworth Ltr. to Reed# 5 Exhibit E--11/6/06 Reed Ltr. to Hollingsworth# 6 Exhibit F--11/10/06 Skidmore Ltr. to Padegimas and Hollingsworth# 7 Exhibit G--10/26/06 Reed Ltr. to Padegimas# 8 Exhibit H--Convergys' First Request for Documents to EEOC# 9 Exhibit I--EEOC's Response to Convergys' First Request for Documents# 10 Exhibit J--8/3/06 Reed Ltr. to Padegimas# 11 Exhibit K--9/8/06 Padegimas Ltr. to Skidmore# 12 Exhibit L--10/5/06 Reed Ltr. to Padegimas# 13 Exhibit M--10/11/06 Padegimas Ltr. to Reed# 14 Exhibit N--EEOC's Privilege Logs (2)# 15 Exhibit O--Affidavit of Catherine Ann Reed)(Reed, Catherine) (Entered: 11/17/2006)

2 Exhibit A--Proposed Order

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3 Exhibit B--EEOC's Initial Rule 26(a)(1) Disclosure Statement

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4 Exhibit C--Richards' Initial Disclosures

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5 Exhibit D--9/22/06 Hollingsworth Ltr. to Reed

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6 Exhibit E--11/6/06 Reed Ltr. to Hollingsworth

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7 Exhibit F--11/10/06 Skidmore Ltr. to Padegimas and Hollingsworth

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8 Exhibit G--10/26/06 Reed Ltr. to Padegimas

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9 Exhibit H--Convergys' First Request for Documents to EEOC

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10 Exhibit I--EEOC's Response to Convergys' First Request for Documents

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11 Exhibit J--8/3/06 Reed Ltr. to Padegimas

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12 Exhibit K--9/8/06 Padegimas Ltr. to Skidmore

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13 Exhibit L--10/5/06 Reed Ltr. to Padegimas

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14 Exhibit M--10/11/06 Padegimas Ltr. to Reed

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15 Exhibit N--EEOC's Privilege Logs (2)

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16 Exhibit O--Affidavit of Catherine Ann Reed

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CERTIFICATE OF SERVICE by Convergys Corporation's Answers to Plaintiff Richards' Second Set of Written Discovery (Skidmore, David) (Entered: 11/22/2006)

**RESTRICTED DOCUMENT** RETURN OF SERVICE Unexecuted for Subpoena and Subpoena Duces Tecum to Stephanie Hills, filed by Defendant Convergys. (O'Brien, Michael) (Entered: 11/22/2006)

MOTION for Summary Judgment filed by Defendant Convergys. (Skidmore, David) (Entered: 12/01/2006)

MEMORANDUM in Support re 70 MOTION for Summary Judgment filed by Defendant Convergys. (Attachments: # 1 Exhibit A# 2 Exhibit A cont# 3 Exhibits B-F# 4 Exhibits G-P# 5 Exhibit Q# 6 Exhibit Q cont.)(Skidmore, David) (Entered: 12/01/2006)

2 Exhibit A

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3 Exhibit A cont

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4 Exhibits B-F

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5 Exhibits G-P

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6 Exhibit Q

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7 Exhibit Q cont.

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MOTION for Partial Summary Judgment filed by Consol Plaintiff Equal Employment Opportunity Commission. (Padegimas, Sandra) (Entered: 12/01/2006)

MEMORANDUM in Support re 72 MOTION for Partial Summary Judgment filed by Consol Plaintiff Equal Employment Opportunity Commission. (Attachments: # 1 Exhibit List and Exhibit 1# 2 Exhibits 2 - 5)(Padegimas, Sandra) (Entered: 12/01/2006)

2 Exhibit List and Exhibit 1

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3 Exhibits 2 - 5

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CERTIFICATE OF SERVICE by Equal Employment Opportunity Commission Plaintiff EEOC's Fourth Supplemental Disclosure (Padegimas, Sandra) (Entered: 12/04/2006)

RESPONSE to Motion re 67 MOTION to Compel discovery filed by Consol Plaintiff Equal Employment Opportunity Commission, Plaintiff Jennifer Richards. (Attachments: # 1 Exhibits 1 - 5)(Padegimas, Sandra) (Entered: 12/04/2006)

2 Exhibits 1 - 5

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MOTION for Leave to File Excess Pages filed by Consol Plaintiff Equal Employment Opportunity Commission, Plaintiff Jennifer Richards. (Attachments: # 1 Text of Proposed Order)(Padegimas, Sandra) (Entered: 12/04/2006)

2 Text of Proposed Order

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CERTIFICATE OF SERVICE by Jennifer Richards Supplemental Disclosures (Hollingsworth, April) (Entered: 12/04/2006)

DOCKET TEXT ORDER granting 76 Motion for Leave to File Excess Pages.IT IS ORDERED that Plaintiffs may have a two and one page extension of the ten page limitation for Plaintiffs' Joint Response to Defendant Convergys' Motion to Compel.Signed by Judge David Nuffer on 12/5/06.No attached document. (Nuffer, David) (Entered: 12/05/2006)

**RESTRICTED DOCUMENT** RETURN OF SERVICE Executed for Subpoena served on Q K Incorporated on 11/16/2006, filed by Defendant Convergys. (Skidmore, David) (Entered: 12/06/2006)

**RESTRICTED DOCUMENT** RETURN OF SERVICE Executed for Subpoena served on Discover Financial Services on 11/14/2006, filed by Defendant Convergys. (Skidmore, David) (Entered: 12/06/2006)

ERRATA to 75 Response to Motion filed by Consol Plaintiff Equal Employment Opportunity Commission. (Attachments: # 1 Affidavit Sandra Padegimas)(Padegimas, Sandra) (Entered: 12/06/2006)

2 Affidavit Sandra Padegimas

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DOCUMENTS LODGED consisting of Order granting motion to file excess pages. This order is duplicative of previous order 78 granting this motion by Magistrate Nuffer (blk, ) (Entered: 12/08/2006)

Plaintiff's MOTION for Protective Order, MOTION to Quash Subpoena filed by Plaintiff Jennifer Richards. (Hollingsworth, April) (Entered: 12/14/2006)

MEMORANDUM in Support re 83 Plaintiff's MOTION for Protective Order MOTION to Quash Subpoena filed by Plaintiff Jennifer Richards. (Attachments: # 1 Exhibit A)(Hollingsworth, April) (Entered: 12/14/2006)

2 Exhibit A

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ORDER re 83 Plaintiff's MOTION for Protective Order MOTION to Quash Subpoena filed by Jennifer Richards.IT IS HEREBY ORDERED that (a) pending disposition of this motion Defendant's counsel shall not use or disseminate any materials received pursuant to the subpoena at issue in this motion and shall not issue subpoenas to or serve subpoenas upon Plaintiff's former and current employers; and(b) on or before December 20, 2006, Defendant shall provide Plaintiff's counsel with copies of any subpoenas issued by Defendant but not served on Plaintiff prior to this date.Signed by Judge David Nuffer on 12/15/06. (Nuffer, David) (Entered: 12/15/2006)

REPLY to Response to Motion re 67 MOTION to Compel discovery filed by Defendant Convergys. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C)(Reed, Catherine) (Entered: 12/18/2006)

2 Exhibit A

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3 Exhibit B

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4 Exhibit C

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RESPONSE to Motion re 83 Plaintiff's MOTION for Protective Order MOTION to Quash Subpoena filed by Defendant Convergys. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C)(Skidmore, David) (Entered: 01/02/2007)

2 Exhibit A

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3 Exhibit B

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4 Exhibit C

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RESPONSE to Motion re 72 MOTION for Partial Summary Judgment filed by Defendant Convergys. (Attachments: # 1 Exhibits A & B# 2 Exhibits C, D & E)(Skidmore, David) (Entered: 01/02/2007)

2 Exhibits A & B

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3 Exhibits C, D & E

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Joint MEMORANDUM in Opposition re 70 MOTION for Summary Judgment filed by Consol Plaintiff Equal Employment Opportunity Commission, Plaintiff Jennifer Richards. (Attachments: # 1 Exhibit List and Exh. 1 -8# 2 Exhibits 8 - 20# 3 Exhibits 21 - 28)(Padegimas, Sandra) (Entered: 01/04/2007)

2 Exhibit List and Exh. 1 -8

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3 Exhibits 8 - 20

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4 Exhibits 21 - 28

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Joint MOTION for Extension of Time to File Response/Reply as to 89 Memorandum in Opposition to Motion, filed by Plaintiff Jennifer Richards. (Attachments: # 1 Text of Proposed Order) Motions referred to David Nuffer.(Hollingsworth, April) (Entered: 01/04/2007)

2 Text of Proposed Order

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ORDER granting 90 Motion for Extension of Time to File Response/Reply re 70 MOTION for Summary Judgment. Replies due by 1/4/2007. Signed by Judge David Nuffer on 1/4/07. (kla) (Entered: 01/04/2007)

MOTION to Continue Trial Setting filed by Consol Plaintiff Equal Employment Opportunity Commission. (Attachments: # 1 Text of Proposed Order) Motions referred to David Nuffer.(Padegimas, Sandra) (Entered: 01/04/2007)

2 Text of Proposed Order

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REPLY to Response to Motion re 72 MOTION for Partial Summary Judgment filed by Consol Plaintiff Equal Employment Opportunity Commission. (Attachments: # 1 Exhibit List and Exhibits 1 - 2)(Padegimas, Sandra) (Entered: 01/04/2007)

2 Exhibit List and Exhibits 1 - 2

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MEMORANDUM DECISION denying 67 Motion to Compel. Signed by Judge David Nuffer on 1/8/07. (blk) (Entered: 01/08/2007)

Amended MOTION to Continue Trial Setting filed by Consol Plaintiff Equal Employment Opportunity Commission. (Attachments: # 1 Text of Proposed Order) Motions referred to David Nuffer.(Shanley, Sally) (Entered: 01/10/2007)

2 Text of Proposed Order

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Defendant's MOTION for Leave to File Excess Pages filed by Defendant Convergys. (Attachments: # 1 Text of Proposed Order Proposed Order Granting Ex Parte Motion for Leave to File Overlength Memo) Motions referred to David Nuffer.(Levin, Ali) (Entered: 01/11/2007)

2 Text of Proposed Order Proposed Order Granting Ex Parte Motion for Leave to File

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ORDER granting 95 Motion to Continue Trial. Vacated hearings: Trial on 4/30/07; Final Pretrial Conference on 4/16/07. To be reset later by the case manager. Signed by Judge Dale A. Kimball on 1/16/07. (blk) (Entered: 01/16/2007)

ORDER granting 96 Motion for Leave to File Excess Pages. Signed by Judge Dale A. Kimball on 1/16/07. (blk) (Entered: 01/17/2007)

REPLY to Response to Motion re 83 Plaintiff's MOTION for Protective Order MOTION to Quash Subpoena filed by Plaintiff Jennifer Richards. (Hollingsworth, April) (Entered: 01/16/2007)