Case: EEOC v. PRODUCTIVITY IMPROVEMENT CENTER

Equal Employment Opportunity Commission v. Productivity Improvement Center, Inc.

Equal Employment Opportunity Commission v. Productivity Improvement Center, Inc.

Equal Employment Opportunity Commission v. Productivity Improvement Center, Inc.

Equal Employment Opportunity Commission v. Productivity Improvement Center, Inc.

Equal Employment Opportunity Commission and Latasha Jackson v. Productivity Improvement Center, Inc.

Equal Employment Opportunity Commission and Latasha Jackson v. Productivity Improvement Center, Inc.

Equal Employment Opportunity Commission and Latasha Jackson v. Productivity Improvement Center, Inc.

Equal Employment Opportunity Commission and Latasha Jackson v. Productivity Improvement Center, Inc.

Equal Employment Opportunity Commission and Latasha Jackson v. Productivity Improvement Center, Inc.

Equal Employment Opportunity Commission and Latasha Jackson v. Productivity Improvement Center, Inc.

Carly Knight, Frank Dobbin, Alexandra Kalev

COMPLAINT against Productivity Improvement Center, Inc. , filed by Equal Employment Opportunity Commission. (Attachments: # 1 Civil Cover Sheet)(THR, ) (Entered: 07/28/2005)

REQUEST FOR WAIVER of Service sent to Alison Tasma, Attorney for Defendant on September 12, 2005 by Equal Employment Opportunity Commission. Waiver of Service due by 10/14/2005. (Agee, Pamela) (Entered: 09/15/2005)

ANSWER to Complaint by Productivity Improvement Center, Inc..(Tasma, Alison) (Entered: 11/08/2005)

Rule 16.1(A) Initial Order Telephonic Case Management Conference set for 1/12/2006 10:15 AM before Magistrate Judge Alfred G. Nicols. (wg, ) (Entered: 11/10/2005)

MOTION to Withdraw as Attorney by Equal Employment Opportunity Commission. (DeLeonardo, Prisca) (Entered: 11/28/2005)

TEXT ONLY ORDER granting 5 Motion to Withdraw as Attorney. Attorney Prisca M. DeLeonardo terminated as attorney for plaintiff. Signed by Judge Alfred G. Nicols on November 29, 2005. NO FURTHER WRITTEN ORDER SHALL ISSUE. (wg, ) (Entered: 11/29/2005)

MOTION to Intervene by Latasha Jackson. (Attachments: # 1 Exhibit EEOC Complaint Against PIC# 2 Exhibit Jackson's Complaint in Intervention)(Brandon, Stephen) (Entered: 01/03/2006)

Minute Entry for proceedings held before Judge Alfred G. Nicols : Telephonic Case Management Conference held on 1/12/2006. Participants: Pamela K. Agee, counsel for plaintiff, and Alison L. Tasma and Jeffrey A. Walker, counsel for defendant. A Schedulingi Order shall be entered by the Court setting this case for trial on a trial calendar commencing 12/04/2006. (wg, )(15) (Entered: 01/18/2006)

NOTICE of Service of Disclosure by Productivity Improvement Center, Inc..(Tasma, Alison) (Entered: 01/13/2006)

RESPONSE in Opposition re 6 MOTION to Intervene filed by Productivity Improvement Center, Inc.. (Attachments: # 1 Exhibit A)(Walker, Jeffrey) (Entered: 01/17/2006)

MEMORANDUM in Support re 8 Response in Opposition to Motion to Intervene filed by Productivity Improvement Center, Inc.. (Walker, Jeffrey) (Entered: 01/17/2006)

ORE TENUS MOTION for leave to file a reply to Defendant's response to Motion to Intervene by Equal Employment Opportunity Commission. ACF (Entered: 01/19/2006)

TEXT ORDER ONLY granting EEOC's Motion for Leave to File Reply to Defendant's response to Motion to Intervene. EEOC to file reply by 1/27/06. NO WRITTEN ORDER TO FOLLOW. Entered by Judge Alfred G. Nicols on 1/19/06. ACF (Entered: 01/19/2006)

SCHEDULING ORDER: Final Pretrial Conference set for 11/9/2006 09:00 AM before District Judge William H. Barbour Jr.. Amended Pleadings due by 2/13/2006. Discovery due by 8/4/2006. Disclosure due by 1/13/2006. Designate Experts Plaintiff Deadline due by 5/4/2006. Designate Experts for Defendant Deadline due by 6/4/2006. Jury Trial set for 12/4/2006 09:00 AM before District Judge William H. Barbour Jr.. Joinder of Parties due by 2/13/2006. Motions due by 8/19/2006. Signed by Judge Alfred G. Nicols on January 20, 2006. (wg, ) (Entered: 01/20/2006)

ORE TENUS MOTION for Extension of Time to File Response/Reply re: motion to intervene by Latasha Jackson. ACF (Entered: 01/24/2006)

ORE TENUS ORDER granting Latasha Jackson's ore tenus Motion for Extension of Time to File Response/Reply re: motion to intervene. Reply to be filed before 1/27/06. NO WRITTEN ORDER TO FOLLOW. Signed by Judge Alfred G. Nicols on 1/24/06. ACF (Entered: 01/24/2006)

REPLY to Response to Motion re 8 Response in Opposition to Motion, 9 Memorandum in Support of Motion to Intervene filed by Equal Employment Opportunity Commission. (Agee, Pamela) (Entered: 01/25/2006)

RESPONSE in Opposition re 6 MOTION to Intervene Reply to Defendant's Response in Opposition to Her Motion to Intervene filed by Latasha Jackson. (Brandon, Stephen) (Entered: 01/27/2006)

NOTICE of Service of Disclosure by Equal Employment Opportunity Commission.(Agee, Pamela) (Entered: 02/01/2006)

ORDER granting 6 Motion to Intervene. Signed by Judge Alfred G. Nicols on 2/2/06. ACF (Entered: 02/02/2006)

MOTION for David J. Middlebrooks to Appear Pro Hac Vice by Latasha Jackson. (THR, ) (Entered: 02/14/2006)

Pro Hac Vice fee paid by David J. Middlebrooks $ 25, receipt number 10903 (THR, ) (Entered: 02/14/2006)

Appellant's BRIEF by Productivity Improvement Center, Inc.. (Tasma, Alison) (Entered: 02/14/2006)

Appellant's BRIEF by Productivity Improvement Center, Inc.. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Exhibit E)(Tasma, Alison) (Entered: 02/14/2006)

MOTION for Review re 14 Order on Motion to Intervene by Productivity Improvement Center, Inc.. (Tasma, Alison) (Entered: 02/15/2006)

MEMORANDUM in Support re 18 MOTION for Review re 14 Order on Motion to Intervene filed by Productivity Improvement Center, Inc.. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Exhibit E)(Tasma, Alison) (Entered: 02/15/2006)

TEXT ONLY ORDER granting 15 Motion to Appear Pro Hac Vice of David J. Middlebrooks on behalf of plaintiff upon the payment of the appropriate fee to the Clerk of the Court and completion of registration for electronic filing. Signed by Judge Alfred G. Nicols on February 15, 2006. NO FURTHER WRITTEN ORDER SHALL ISSUE. (wg, ) (Entered: 02/15/2006)

NOTICE of Service of Interrogatories by Equal Employment Opportunity Commission.(Agee, Pamela) (Entered: 02/16/2006)

NOTICE of Service of Request for Production by Equal Employment Opportunity Commission.(Agee, Pamela) (Entered: 02/16/2006)

NOTICE to Take Deposition (videotaped) of Cheryl Harris by Productivity Improvement Center, Inc..(Walker, Jeffrey) (Entered: 02/21/2006)

Case reassigned to Judge James C. Sumner. Judge Alfred G. Nicols no longer assigned to the case, pursuant to Administrative Order signed by Chief Judge Wingate on January 30, 2006. (THR, ) (Entered: 03/01/2006)

Response in Opposition re 18 MOTION for Review re 14 Order on Motion to Intervene by Productivity Improvement Center, Inc.. (Tasma, Alison), 19 MEMORANDUM in Support re 18 MOTION for Review re 14 Order on Motion to Intervene filed by Productivity Improvement Center, Inc.. (Attachments: # (1) Exhibit A# (2) Exhibit B# (3) Exhibit C# (4) Exhibit D# (5) Exhibit E)(Tasma, Alison) filed by Equal Employment Opportunity Commission. (Agee, Pamela) (Entered: 02/23/2006)

MOTION for Extension of Time to File Response/Reply as to 23 Response in Opposition, Latasha Jackson's Motion for Additional Time to Respond to Defendant's Appeal from Magistrate Judge's Ruling Granting Plaintiff's Motion to Intervene by Latasha Jackson. (Brandon, Stephen) (Entered: 02/28/2006)

MOTION for Entry of Default by Latasha Jackson. (Attachments: # 1 Exhibit A)(Brandon, Stephen) (Entered: 02/28/2006)

ANSWER to Complaint IN INTERVENTION by Productivity Improvement Center, Inc..(Tasma, Alison) (Entered: 02/28/2006)

RESPONSE in Opposition re 25 MOTION for Entry of Default filed by Productivity Improvement Center, Inc.. (Walker, Jeffrey) (Entered: 02/28/2006)

MEMORANDUM in Support re 27 Response in Opposition to Motion (for Entry of Default filed by Latasha Jackson) filed by Productivity Improvement Center, Inc.. (Walker, Jeffrey) (Entered: 02/28/2006)

RESPONSE to 18 Motion for Review of Magistrate Judge's Ruling Granting Plaintiff's Motion to Intervene filed by Latasha Jackson. (Brandon, Stephen) Modified on 3/14/2006 (DT, ). (Entered: 03/03/2006)

REPLY to Response to Motion re 23 Response in Opposition, filed by Productivity Improvement Center, Inc.. (Walker, Jeffrey) (Entered: 03/03/2006)

TEXT ONLY ORDER GRANTING 24 Motion for Extension of Time to File A Response to Defendant's Appeal from Magistrate Judge's Ruling Granting Plaintiff's Motion to Intervene. Response date shall be no later than March 3, 2006. NO WRITTEN ORDER SHALL ISSUE. Signed by Judge William H. Barbour Jr. on 03-03-06. (Lewis, Nijah) (Entered: 03/03/2006)

MOTION to Withdraw as Attorney Stephen A. Brandon by Latasha Jackson. (Brandon, Stephen) (Entered: 03/03/2006)

TEXT ORDER ONLY granting 32 Motion to Withdraw as Attorney. Attorney Stephen A. Brandon terminated. NO WRITTEN ORDER TO FOLLOW. Entered by Judge James C. Sumner on 3/3/06. ACF (Entered: 03/03/2006)

REPLY to Response to Motion re 30 Response to Motion filed by Productivity Improvement Center, Inc.. (Walker, Jeffrey) (Entered: 03/10/2006)

DOCKET ANNOTATION as to # 30. Incorrect linkage to document # 27; correct linkage made to document # 18. (DT, ) (Entered: 03/14/2006)

NOTICE of Service of Response to Interrogatories by Productivity Improvement Center, Inc..(Tasma, Alison) (Entered: 03/20/2006)

NOTICE of Service of Response to Request for Production by Productivity Improvement Center, Inc..(Tasma, Alison) (Entered: 03/20/2006)

MOTION to Substitute Attorney by Equal Employment Opportunity Commission. (Russell, Ermea) (Entered: 04/04/2006)

ORDER granting 36 Motion to Substitute Attorney. Added attorney James L. Lee Gwendolyn Young Reams, C. Emanuel Smith, Mildred Byrd, Ermea J. Russell, Naomi Hilton Archer for Equal Employment Opportunity Commission. Signed by Judge James C. Sumner on 04/06/06. (THR, ) (Entered: 04/10/2006)

MOTION to Compel Discovery by Productivity Improvement Center, Inc.. (Attachments: # 1 Deposition Excerpts of Cheryl Harris)(Walker, Jeffrey) (Entered: 04/11/2006)

MEMORANDUM in Support re 38 MOTION to Compel Discovery filed by Productivity Improvement Center, Inc.. (Walker, Jeffrey) (Entered: 04/11/2006)

ORDER denying Defendant's 18 Appeal of Magistrate Judge's Ruling; denying Plaintiff / Intervenor's 25 Motion for Entry of Default. Plaintiff / Intervenor must file her Complaint in Intervention by April 27, 2006, and Defendant must file its Answer to Complaint in Intervention in a timely manner thereafter. Signed by Judge William H. Barbour Jr. on 04-20-06. (Turner, Tom)

MOTION to Withdraw as Counsel for Plaintiff by Latasha Jackson. (Middlebrooks - PHV, David) (Entered: 04/25/2006)

DOCKET ANNOTATION as to #41. Attorney to refile attachment #1 as a separate pleading. Attachment #3 Order has been emailed to Judge's chambers. (Moore, Janet) (Entered: 04/25/2006)

MEMORANDUM in Support re 41 MOTION for Extension of Time to File Response/Reply filed by Equal Employment Opportunity Commission. (Attachments: # 1)(Russell, Ermea) (Entered: 04/25/2006)

First Intervenor COMPLAINT EEOC v. PIC , filed by Latasha Jackson.(Brown, Michael) (Entered: 04/26/2006)

ANSWER to Intervenor Complaint of Latasha Jackson by Productivity Improvement Center, Inc..(Walker, Jeffrey) (Entered: 04/27/2006)

TEXT ORDER ONLY granting 42 Motion to Withdraw as Counsel. David J. Middlebrooks granted leave of Court to withdraw from representing Plaintiff. NO WRITTEN ORDER TO FOLLOW. Signed by Judge James C. Sumner on 5/1/06. ACF (Entered: 05/01/2006)

RESPONSE in Opposition re 38 MOTION to Compel Discovery filed by Equal Employment Opportunity Commission. (Attachments: # 1 Exhibit)(THR, ) (Entered: 05/16/2006)

MEMORANDUM IN SUPPORT re 46 Response in Opposition to Motion filed by Equal Employment Opportunity Commission. (Attachments: # 1 Exhibit)(THR, ) (Entered: 05/16/2006)

NOTICE OF CONVENTIONAL FILING by Equal Employment Opportunity Commission re 46 Response in Opposition to Motion, 47 Memorandum in Support (THR, ) (Entered: 05/16/2006)

MOTION for Extension of Time to File Defendant's Expert Designation, to Extend The Discovery Deadline, and The Motion Deadline by Productivity Improvement Center, Inc.. (Tasma, Alison) (Entered: 05/16/2006)

MOTION for Extension of Time to File Response/Reply as to 46 Response in Opposition to Motion to Compel EEOC Testimony by Productivity Improvement Center, Inc.. (Tasma, Alison) (Entered: 05/18/2006)

TEXT ORDER ONLY granting Defendant's 50 Motion for Extension of Time to File Reply in support of its Motion to Compel EEOC Testimony. Reply to be filed by 5/26/2006. NO WRITTEN ORDER TO FOLLOW. Entered by Judge James C. Sumner on 5/18/06. ACF (Entered: 05/18/2006)

Response in Opposition re 49 MOTION for Extension of Time to File Defendant's Expert Designation, to Extend The Discovery Deadline, and The Motion Deadline by Productivity Improvement Center, Inc.. (Tasma, Alison) filed by Equal Employment Opportunity Commission. (Russell, Ermea) (Entered: 05/18/2006)

NOTICE of Change of Address by Michael R. Brown (Brown, Michael) (Entered: 05/19/2006)

RESPONSE in Opposition re 49 MOTION for Extension of Time to File Defendant's Expert Designation, to Extend The Discovery Deadline, and The Motion Deadline filed by Latasha L. Jackson. (Brown, Michael) (Entered: 05/22/2006)

MOTION to Compel FRCP 35 Examination by Productivity Improvement Center, Inc.. (Attachments: # 1 Exhibit A - Complaint# 2 Exhibit B - Complaint in Intervention# 3 Exhibit C - CV of Dr. Mark Webb)(Tasma, Alison) (Entered: 05/22/2006)

NOTICE to Take Deposition (Videotaped) of Latasha Jackson by Productivity Improvement Center, Inc..(Tasma, Alison) (Entered: 05/24/2006)

Mail Returned as Undeliverable. Containing document #40. Mail sent to C. Emanuel Smith, Attorney. (THR, ) (Entered: 05/24/2006)

NOTICE of Service of Interrogatories by Productivity Improvement Center, Inc..(Tasma, Alison) (Entered: 05/24/2006)

NOTICE of Service of Request for Production by Productivity Improvement Center, Inc..(Tasma, Alison) (Entered: 05/24/2006)

RESPONSE in Support re 49 MOTION for Extension of Time to File Defendant's Expert Designation, to Extend The Discovery Deadline, and The Motion Deadline filed by Productivity Improvement Center, Inc.. (Attachments: # 1 Exhibit A# 2 Exhibit B)(Tasma, Alison) (Entered: 05/26/2006)

MEMORANDUM in Support re 38 MOTION to Compel Discovery EEOC Deposition Testimony filed by Productivity Improvement Center, Inc.. (Attachments: # 1 Exhibit A)(Tasma, Alison) (Entered: 05/26/2006)

MEMORANDUM in Support re 38 MOTION to Compel Discovery EEOC Deposition Testimony filed by Productivity Improvement Center, Inc.. (Attachments: # 1 Exhibit A)(Tasma, Alison) (Entered: 05/26/2006)

DOCKET ANNOTATION as to #60 inadvertently attached incorrect PDF. Attorney refiled, document #61 replaces document #60. (THR, ) (Entered: 05/30/2006)

ORDER granting Defendant's 49 Motion for Extension of Expert Designation Deadline, Discovery Deadline, and Motion Deadline. Signed by Judge James C. Sumner on 5/31/06. ACF (Entered: 05/31/2006)

Set Deadlines/Hearings: Discovery due by 9/1/2006. Designate Experts for Defendant Deadline due by 7/5/2006. Motions due by 9/11/2006. ACF (Entered: 05/31/2006)

Designation of Experts by Productivity Improvement Center, Inc.. (Attachments: # 1 Exhibit A)(Tasma, Alison) (Entered: 06/05/2006)

NOTICE to Take Deposition (Amended) via Videotape of Latasha Jackson by Productivity Improvement Center, Inc..(Tasma, Alison) (Entered: 06/14/2006)

NOTICE to Take Deposition of Dr. Krishan Gupta by Productivity Improvement Center, Inc..(Tasma, Alison) (Entered: 06/15/2006)

TEXT ORDER ONLY granting 54 Defendant's Motion to Compel Rule 35 Exam; no response filed in opposition. NO WRITTEN ORDER TO FOLLOW. Entered by Judge James C. Sumner on 6/15/06. ACF (Entered: 06/15/2006)

ORDER granting 38 Defendant's Motion to Compel. Signed by Judge James C. Sumner on 6/19/06. EF (Entered: 06/19/2006)

NOTICE to Take Deposition of PIC 30(b)(6) by Equal Employment Opportunity Commission.(Russell, Ermea) (Entered: 06/20/2006)

First MOTION for Protective Order Re Rule 35 Examination by Equal Employment Opportunity Commission. (Attachments: # 1 Memorandum in Support# 2 Text of Proposed Order Protective Order)(Russell, Ermea) (Entered: 06/21/2006)

Emergency MOTION for Protective Order by Productivity Improvement Center, Inc.. (Attachments: # 1 Exhibit A# 2 Exhibit B)(Walker, Jeffrey) (Entered: 06/22/2006)

RESPONSE in Opposition re 69 Emergency MOTION for Protective Order filed by Equal Employment Opportunity Commission. (Russell, Ermea) (Entered: 06/22/2006)

RESPONSE MEMORANDUM in Support re 69 Emergency MOTION for Protective Order filed by Productivity Improvement Center, Inc.(Walker, Jeffrey) (Entered: 06/22/2006)

ORDER granting 69 Defendant PIC's Motion for Protective Order. Signed by Judge James C. Sumner on 6/23/06. ACF (Entered: 06/23/2006)

MEMORANDUM in Opposition re 68 First MOTION for Protective Order Re Rule 35 Examination filed by Productivity Improvement Center, Inc.. (Tasma, Alison) (Entered: 06/23/2006)

ATTACHMENT re 73 Memorandum in Opposition to Motion for Protective Order - (Exhibit A) by Productivity Improvement Center, Inc.. (Tasma, Alison) (Entered: 06/23/2006)

ATTACHMENT re 73 Memorandum in Opposition to Motion for Protective Order - (Exhibit B) by Productivity Improvement Center, Inc.. (Tasma, Alison) (Entered: 06/23/2006)

MOTION for Protective Order (For Consideration of EEOC's Motion for a Protective Order and to Shorten EEOC's Reply Time by Productivity Improvement Center, Inc.. (Tasma, Alison) (Entered: 06/23/2006)

ORDER denying Plaintiff's 68 Motion for Protective Order, granting 76 Defendant's request for expedited ruling on EEOC's Motion for Protective Order. Signed by Judge James C. Sumner on 6/28/06. ACF (Entered: 06/28/2006)

NOTICE to Take Deposition of Lisa Jones by Productivity Improvement Center, Inc..(Walker, Jeffrey) (Entered: 07/03/2006)

NOTICE of Service of Interrogatories by Productivity Improvement Center, Inc. (Tasma, Alison) Modified on 7/5/2006 (Lowery, R.). (Entered: 07/03/2006)

NOTICE of Service of Interrogatories by Productivity Improvement Center, Inc..(Tasma, Alison) (Entered: 07/03/2006)

MOTION for Review re 66 Order on Motion to Compel by Equal Employment Opportunity Commission. (Russell, Ermea) (Entered: 07/03/2006)

NOTICE of Appearance by James B. Galloway on behalf of Productivity Improvement Center, Inc. (Galloway, James) (Entered: 07/05/2006)

NOTICE of Service of Expert Designation by Productivity Improvement Center, Inc. (Tasma, Alison) (Entered: 07/05/2006)

NOTICE of Service of Response to Interrogatories by Equal Employment Opportunity Commission.(Russell, Ermea) (Entered: 07/05/2006)