Case: EEOC v. CONSOLIDATED RESORTS, INC.

U.S. Equal Employment Opportunity Commission v. Consolidated Resorts

EEOC v. Consolidated Resorts, Inc.

EEOC v. Consolidated Resorts, Inc.

EEOC v. Consolidated Resorts, Inc.

EEOC v. Consolidated Resorts, Inc.

EEOC v. Consolidated Resorts, Inc.

U.S. Equal Employment Opportunity Commission v. Consolidated Resorts, Inc.

Carly Knight, Frank Dobbin, Alexandra Kalev

COMPLAINT - Title VII Civil Rights - Sexual Harassment, National Origin, Retaliation against Consolidated Resorts, filed by U.S. Equal Employment Opportunity Commission. Certificate of Interested Parties due by 9/17/2006. (Attachments: # 1 Civil Cover Sheet # 2 Summons)(Park, Anna) (Entered: 09/07/2006)

SUMMONS Issued as to Consolidated Resorts. (GEW) (Entered: 09/07/2006)

Case assigned to Judge Lloyd D. George and George W Foley, Jr. (GEW)

AMENDED COMPLAINT with Jury Demand against all defendants, filed by U.S. Equal Employment Opportunity Commission.(Park, Anna) (Entered: 09/13/2006)

ORDER for Certificate of Interested Parties. IT IS ORDERED that counsel for Plaintiff shall have a period of 10 calendar days from the filing date of this order within which to fully comply with the provisions of Local Rule 10-6. Certificate of Interested Parties due by 9/27/2006. Signed by Judge George W Foley Jr. on 9/18/06. (MAJ) (Entered: 09/21/2006)

CERTIFICATE OF SERVICE by Plaintiff U.S. Equal Employment Opportunity Commission re 2 Summons Issued, 3 Amended Complaint. (Johnson, Dana) (Entered: 01/05/2007)

ANSWER to 3 Amended Complaint defendant Consolidated Resorts, Inc.'s answer to plaintiff's First Amended Complaint by Defendant Consolidated Resorts.(Westbrook, Deborah) (Entered: 01/10/2007)

CERTIFICATE of Interested Parties defendant's Certificate of Interested parties by Defendant Consolidated Resorts. (Westbrook, Deborah) (Entered: 01/10/2007)

ORDER Scheduling Early Neutral Evaluation Session: Early Neutral Evaluation set for 3/12/2007 09:30 AM in LV Chambers 3C before Magistrate Judge Lawrence R. Leavitt. Signed by Judge Lawrence R. Leavitt on 1/23/07. (AXM) (Entered: 01/29/2007)

MINUTE ORDER IN CHAMBERS of the Honorable Lawrence R. Leavitt, U.S. Magistrate Judge on 1/30/2007. At the request of counsel and for good cause shown the ENE session presently scheduled for 9:30 a.m. on March 12, 2007 before Judge Leavitt is hereby rescheduled for 9:30 A.M. ON THURSDAY, MARCH 29, 2007 in Room 3014. The written evaluation statements shall be submitted to chambers not later than March 22, 2007. (no image attached) (CAP, ) (Entered: 01/30/2007)

PROPOSED Discovery Plan/Scheduling Order filed by Plaintiff U.S. Equal Employment Opportunity Commission Special Scheduling Review Requested. (Attachments: # 1 Signature Page)(Johnson, Dana) (Entered: 02/15/2007)

MOTION to Dismiss DEFENDANT'S MOTION TO DISMISS OR, IN THE ALTERNATIVE, MOTION FOR SUMMARY JUDGMENT by Defendant Consolidated Resorts. Responses due by 3/6/2007. (Attachments: # 1 Exhibit A-C# 2 Exhibit D# 3 Exhibit E# 4 Exhibit F-H# 5 Exhibit I)(Westbrook, Deborah) (Entered: 02/16/2007)

MOTION to Continue District Judge Hearing On Defendant's Motion for Summary Judgment by Plaintiff U.S. Equal Employment Opportunity Commission. Responses due by 3/11/2007. (Johnson, Dana) Additional attachment(s) added on 2/22/2007 (GEW, ). (Entered: 02/21/2007)

ERROR: Document should have been filed as an attachment to motion 12 . Attorney notified by email. Attached to motion by the Court. Modified on 2/22/2007 (GEW). (Entered: 02/21/2007)

NOTICE of Docket Correction to 13 Affidavit: Document should have been filed as an attachment to motion 12 . Attorney notified by email. Attached to motion by the Court. (no image attached)(GEW)

SCHEDULING ORDER on 10 Proposed Discovery Plan. Discovery due by 10/1/2007. Motions due by 11/30/2007. Proposed Joint Pretrial Order due by 12/30/2007. Signed by Judge George W Foley Jr. on 2/21/07. (AXM) (Entered: 02/23/2007)

RESPONSE to 11 MOTION to Dismiss DEFENDANT'S MOTION TO DISMISS OR, IN THE ALTERNATIVE, MOTION FOR SUMMARY JUDGMENT; filed by Plaintiff U.S. Equal Employment Opportunity Commission. Replies due by 3/20/2007. (Attachments: # 1 Declaration of Erin Dawson# 2 Declaration of Barbara J. Tucker# 3 Exhibit to Declaration of Barbara J. Tucker)(Johnson, Dana) Modified on 3/7/2007 Attorney notified to REFILE Motion for Summary Judgment as a separate document (GEW). Modified on 3/14/2007 Declaration of Barbara J. Tucker and Exhibit to declaration of Barbara J. Tucker SEALED(GEW). (Entered: 03/06/2007)

RESPONSE to 12 MOTION to Continue District Judge Hearing On Defendant's Motion for Summary Judgment; filed by Defendant Consolidated Resorts. DEFENDANT'S OPPOSITION TO PLAINTIFF EEOC'S RULE 56(f) MOTION FOR DENIAL OR SUSPEND HEARING ON DEFENDANT'S MOTION FOR SUMMARY JUDGMENT (Attachments: # 1 Declaration of Deborah L. Westbrook)(Westbrook, Deborah) (Entered: 03/09/2007)

MOTION to Seal 15 Response to Motion to Dismiss, Motion to Place Exhibits to Tucker Declaration Under Seal by Plaintiff U.S. Equal Employment Opportunity Commission. (Johnson, Dana) (Entered: 03/13/2007)

DECLARATION to Motion to Seal 17 MOTION to Seal 15 Response to Motion to Dismiss, Motion to Place Exhibits to Tucker Declaration Under Seal, 15 Response to Motion to Dismiss, Declaration of Dana Johnson in Support of Plaintiff EEOC's Motion to Place Exhibits Under Seal by Plaintiff U.S. Equal Employment Opportunity Commission. (Attachments: # 1 Index Index of Exhibits# 2 Exhibit Exhibits 1-8# 3 Exhibit Exhibits 9-16)(Johnson, Dana) Modified on 3/14/2007 Exhibits #2 and #3 SEALED(GEW). Modified on 3/21/2007 to correct entry (GEW). (Entered: 03/13/2007)

REPLY to Response to 11 MOTION to Dismiss DEFENDANT'S MOTION TO DISMISS OR, IN THE ALTERNATIVE, MOTION FOR SUMMARY JUDGMENT; filed by Defendant Consolidated Resorts. REPLY IN SUPPORT OF DEFENDANT'S MOTION TO DISMISS OR, IN THE ALTERNATIVE, MOTION FOR SUMMARY JUDGMENT (Attachments: # 1 Declaration of Jim Monoyudis# 2 Declaration of John M. Lindros# 3 Declaration Brent Gunson)(Westbrook, Deborah) (Entered: 03/20/2007)

REPLY to Response to 12 MOTION to Continue District Judge Hearing On Defendant's Motion for Summary Judgment; filed by Plaintiff U.S. Equal Employment Opportunity Commission. (Johnson, Dana) (Entered: 03/20/2007)

ORDER granting 17 Motion to Seal Declaration of Barbara J. Tucker attached to 15 Response to Motion to Dismiss. Signed by Judge Lloyd D. George on 3/22/07. (AAB) (Entered: 03/23/2007)

MINUTES OF PROCEEDINGS - Early Neutral Evaluation Conference held on 3/29/2007 before Judge Lawrence R. Leavitt.Pla Counsel: Dana C. Johnson; Def Counsel: Patrick H. Hicks; Kevin J. Blair, General Counsel, also present; Time of Hearing: 9:30 a.m.. Counsel,the parties and the court met and conferred. No settlement was reached. See Order for specific details. Telephonic Status Conference set for 5/7/2007 11:00 AM in Chambers before Magistrate Judge Lawrence R. Leavitt. Mr. Hicks will initiate the telephone conference call. (CAP, ) (Entered: 03/29/2007)

MOTION to Amend/Correct Complaint re 3 Amended Complaint. by Plaintiff U.S. Equal Employment Opportunity Commission. Responses due by 4/28/2007. (Attachments: # 1 Exhibit 1 - Second Amended Complaint)(Johnson, Dana) (Entered: 04/10/2007)

STIPULATION STIPULATION AND [PROPOSED] ORDER CONTINUING DEADLINE TO DESIGNATE EXPERT WITNESSES AND CONDUCT RELATED DISCOVERY by Plaintiff U.S. Equal Employment Opportunity Commission. (Johnson, Dana) (Entered: 04/25/2007)

ORDER ON STIPULATION granting 24 Stipulation on discovery deadlines, SCHEDULING ORDER. Discovery due by 10/31/2007. Motions due by 11/30/2007. Proposed Joint Pretrial Order due by 12/30/2007. Signed by Judge George W Foley Jr. on 4/30/07. (AXM) (Entered: 05/02/2007)

MINUTES OF PROCEEDINGS - Status Conference held on 5/7/2007 before Judge Lawrence R. Leavitt.Pla Counsel: Dana C. Johnson; Def Counsel: Deborah Westbrook; Time of Hearing: 11:00 a.m.. The court and counsel discussed the status of preliminary discovery. This case should be returned to the normal litigation track. (CAP, ) (Entered: 05/07/2007)

MINUTE ORDER IN CHAMBERS of the Honorable George W Foley Jr., U.S. Magistrate Judge, on 5/11/2007. By Judicial Assistant: Julia Hill. RE: 27 Plaintiff's SEALED MOTION for Protective Order Pursuant to FRCP 26 and FRE 412 -- Motion Hearing set for THURSDAY, JUNE 14, 2007, at 9:30 AM in LV Courtroom 3A before Magistrate Judge George W Foley Jr.(no image attached) (JXH) (Entered: 05/11/2007)

STIPULATION re 25 Order on Stipulation, Scheduling Order, 14 Scheduling Order ; Extending Discovery Deadlines [First Request] by Plaintiff U.S. Equal Employment Opportunity Commission, Defendant Consolidated Resorts. (Taylor, Karyn) (Entered: 07/19/2007)

ORDER ON STIPULATION Denying 34 Stipulation to Extend Discovery Deadlines. Proposed Stipulation Extending Discovery Deadlines due by 8/3/2007. Signed by Judge George W Foley Jr. on 07/24/07. (Copies have been distributed pursuant to the NEF - SRK) (Entered: 07/25/2007)

STIPULATION re 35 Order on Stipulation,, Set/Reset Deadlines, ; Extending Discovery Deadlines; Order [First Request] by Plaintiff U.S. Equal Employment Opportunity Commission, Defendant Consolidated Resorts. (Taylor, Karyn) (Entered: 07/31/2007)

ORDER ON STIPULATION granting 36 Stipulation for new SCHEDULING ORDER. Discovery due by 1/29/2008.,Motions due by 3/31/2008.,Proposed Joint Pretrial Order due by 4/30/2008. Signed by Judge George W Foley Jr. on 8/1/07. (Copies have been distributed pursuant to the NEF - AXM) Modified date on 8/7/2007. (Jaime, Melissa) (Entered: 08/03/2007)

MOTION for Protective Order Defendant's Motion for Protective Order [EMERGENCY HEARING REQUESTED] by Defendant Consolidated Resorts. (Attachments: # 1 Exhibit A# 2 Exhibit b# 3 Exhibit C, D, E# 4 Exhibit F, G)(Westbrook, Deborah) (Entered: 09/21/2007)

MINUTE ORDER IN CHAMBERS of the Honorable George W Foley Jr., U.S. Magistrate Judge, on 9/24/2007. By Judicial Assistant: Julia Hill. RE: 38 Defendant's Motion For Protective [ EMERGENCY HEARING REQUESTED] -- Motion Hearing set for FRIDAY, OCTOBER 5, 2007, at 1:30 PM in LV Courtroom 3A before Magistrate Judge George W Foley Jr. Opposition is due October 1, 2007 and Reply is due October 3, 2007. (Copies have been distributed pursuant to the NEF - JBH) (Entered: 09/24/2007)

ORDER Granting 12 Motion for Denial or Suspension of Hearing on Defendants' 11 Motion for Summary Judgment. Denying Without Prejudice the 11 Motion to Dismiss, or in the alternative, Motion for Summary Judgment. Signed by Judge Lloyd D. George on 09/28/07. (Copies have been distributed pursuant to the NEF - SRK) (Entered: 09/28/2007)

RESPONSE to 38 MOTION for Protective Order [ EMERGENCY HEARING REQUESTED] filed by Plaintiff U.S. Equal Employment Opportunity Commission. Replies due by 10/15/2007. (Attachments: # 1 Declaration Declaration of Dana C.Johnson in Support of Plaintiff EEOC's Opposition to Defendant's Motion for a Protective Order and Cross-Motion for and Order Compelling Documents and Responses to Questions at Deposition and Permission to Take Depositions in Excess o# 2 Exhibit Exhibits A through C)(Johnson, Dana) Modified text on 10/4/2007. (MAJ) (Entered: 10/01/2007)

CROSS-MOTION for and Order Compelling Documents and Responses to Questions at Deposition and Permission to Take Depositions in Excess of Seven Hours by Plaintiff U.S. Equal Employment Opportunity Commission. Responses due by 10/19/2007. (MAJ) (Entered: 10/04/2007)

REPLY to Response to 38 MOTION for Protective Order Defendant's Motion For Protective [ EMERGENCY HEARING REQUESTED] ; filed by Defendant Consolidated Resorts. (Westbrook, Deborah) (Entered: 10/03/2007)

RESPONSE to 43 CROSS-MOTION to Compel filed by Defendant Consolidated Resorts. Replies due by 10/17/2007. (MAJ) (Entered: 10/04/2007)

NOTICE of Docket Correction to 41 Response to Motion to Compel, 42 Reply to Response to Motion; ERROR: PDF should have been filed as two separate entries; CORRECTION: Document re-filed by Court as 43 CROSS-MOTION to Compel and 44 Response to Motion to Compel. (no image attached)(MAJ)

MINUTES OF PROCEEDINGS - Motion Hearing held on 10/5/2007 before Judge George Foley Jr. Crtrm Administrator: Donna Smith; Pla Counsel: Dana Johnson; Def Counsel: Deborah Westbrook; FTR #: 1:22:41 - 2:58:28; Time of Hearing: 1:30 p.m.; Courtroom: 3A; RE: 38 MOTION for Protective Order EMERGENCY HEARING REQUESTED, 43 MOTION to Compel. The Court hears the representations of counsel. The Court suggests counsel discuss the scope of the discovery being sought regarding the Blair deposition after this hearing. If counsel can reach agreement regarding this issue, a stipulation and proposed order should be submitted to the Court. If the parties are unable to reach agreement, supplemental briefs regarding this issue are due by 10/12/2007. The Court takes the motions under submission. A separate written order will issue. (no image attached) (Copies have been distributed pursuant to the NEF - DES) (Entered: 10/05/2007)

STIPULATION re 45 Motion Hearing,,, ; STIPULATION REGARDING APPROVED DEPOSITION QUESTIONS FOR KEVIN BLAIR by Plaintiff U.S. Equal Employment Opportunity Commission, Defendant Consolidated Resorts. (Westbrook, Deborah) (Entered: 10/11/2007)

ORDER ON STIPULATION granting 46 Stipulation approving deposition question. Signed by Judge George W Foley Jr. on 10/11/07. (Copies have been distributed pursuant to the NEF - AXM) (Entered: 10/16/2007)

ORDER temporarily unsealing transcript 32 Motion Hearing. Signed by Judge George W Foley Jr.. (Copies have been distributed pursuant to the NEF - AXM) (Entered: 10/18/2007)

STIPULATION Stipulation and Protective Order Regarding Confidentiality of Third Party Personnel Files by Plaintiff U.S. Equal Employment Opportunity Commission. (Johnson, Dana) (Entered: 10/18/2007)

NOTICE by Defendant Consolidated Resorts NOTICE OF WITHDRAWAL AS COUNSEL BY DEBORAH L. WESTBROOK (Westbrook, Deborah) (Entered: 10/18/2007)

ORDER Granting 23 Motion to Amend/Correct Complaint. Signed by Judge Lloyd D. George on 10/22/07. (Copies have been distributed pursuant to the NEF - AXM) (Entered: 10/25/2007)

ORDER ON STIPULATION granting 49 Stipulation and Protective Order Regarding Confidentiality of Third Party Personnel Files. Signed by Judge George W Foley Jr. on 10/19/07. (Copies have been distributed pursuant to the NEF - AXM) (Entered: 10/24/2007)

ORDER Granting in part and denying in part 38 Motion for Protective Order. Signed by Judge George W Foley Jr. on 10/25/07. (Copies have been distributed pursuant to the NEF - AXM) (Entered: 10/30/2007)

ORDER: Defendant produce to Plaintiff information and documents regarding the 03/06/06 complaint against Mr. Rouco in accordance with the provisions regarding the production of such records set forth in the 54 Court's Order. Signed by Judge George W Foley Jr. on 11/07/07. (Copies have been distributed pursuant to the NEF - SRK) (Entered: 11/09/2007)

STIPULATION and [Proposed] Order Extending Discovery Deadlines [Third Request] by Plaintiff U.S. Equal Employment Opportunity Commission, Defendant Consolidated Resorts. (Taylor, Karyn) (Entered: 11/13/2007)

ORDER ON STIPULATION re 57 Stipulation. SCHEDULING ORDER. Discovery due by 5/28/2008. Discovery Motions due by 6/27/08. Dispositive Motions due by 7/25/2008. Proposed Joint Pretrial Order due by 8/25/2008. Signed by Judge George W Foley Jr. on 11/14/07. (Copies have been distributed pursuant to the NEF - OXC) (Entered: 11/16/2007)

STIPULATION and [Proposed] Order Extending Discovery Deadlines by Plaintiff U.S. Equal Employment Opportunity Commission. (Johnson, Dana) (Entered: 02/21/2008)

MOTION to Compel Submission to Independent Mental Examination; Memorandum of Points and Authorities in Support Thereof by Defendant Consolidated Resorts. Responses due by 3/11/2008. (Attachments: # 1 Declaration Karyn M. Taylor, # 2 Exhibit A to B, # 3 Exhibit C to D, # 4 Exhibit E to L, # 5 Exhibit M to N, # 6 Exhibit O, # 7 Exhibit P to Q)(Taylor, Karyn) (Entered: 02/22/2008)

MINUTE ORDER IN CHAMBERS of the Honorable Magistrate Judge George W Foley, Jr, on 2/26/2008. By Judicial Assistant: Julia Hill. RE: 63 Defendant's MOTION to Compel Submission to Independent Mental Examination -- Motion Hearing set for Thursday, April 3, 2008, at 9:30 AM in LV Courtroom 3A before Magistrate Judge George W Foley Jr. (Copies have been distributed pursuant to the NEF - JBH) (Entered: 02/26/2008)

ORDER ON STIPULATION granting 62 Stipulation to extend discovery. Signed by Magistrate Judge George W Foley, Jr on 2/26/08. (Copies have been distributed pursuant to the NEF - AXM) (Entered: 02/28/2008)

MOTION to Seal 63 MOTION to Compel Submission to Independent Mental Examination; Memorandum of Points and Authorities in Support Thereof MOTION TO FILE EXHIBIT UNDER SEAL by Defendant Consolidated Resorts. Motion ripe 2/27/2008. (Taylor, Karyn) (Entered: 02/27/2008)

ORDER granting 65 Motion to Seal Exhibit E to motion #63. Signed by Magistrate Judge George W Foley, Jr on 3/5/08. (Copies have been distributed pursuant to the NEF - AXM) (Entered: 03/05/2008)

RESPONSE to 63 MOTION to Compel Submission to Independent Mental Examination; Memorandum of Points and Authorities in Support Thereof, filed by Plaintiff U.S. Equal Employment Opportunity Commission. Replies due by 3/24/2008. (Attachments: # 1 Declaration of Dana C. Johnson and Exhibit B in Support of Plaintiff EEOC' s Response in Opposition to Defendant's Motion to Compel Submission to Independent Mental Examination, # 2 Declaration of Erin Dawson in Support of Plaintiff EEOC's Response in Opposition to Defendant's Motion to Compel Submission to Independent Mental Examination, # 3 Declaration of Manuel Saint Martin, MD, JD in Support of Plaintiff's Opposition to Compel Independent Mental Examination, # 4 Proof of Service)(Johnson, Dana) (Entered: 03/10/2008)

STIPULATION re 63 MOTION to Compel Submission to Independent Mental Examination; Memorandum of Points and Authorities in Support Thereof, 68 Response to Motion,,, ; STIPULATION TO EXTEND TIME FOR DEFENDANT TO FILE REPLY TO MOTION TO COMPEL SUBMISSION TO INDEPENDENT MEDICAL EXAMINATION; ORDER [FIRST REQUEST] by Plaintiff U.S. Equal Employment Opportunity Commission, Defendant Consolidated Resorts. (Taylor, Karyn) (Entered: 03/20/2008)

ORDER ON STIPULATION granting 69 Stipulation, for time: 63 MOTION to Compel Submission to Independent Mental Examination; Memorandum of Points and Authorities in Support Thereof, Replies due by 3/28/2008. Signed by Magistrate Judge George W Foley, Jr on 3/25/08. (Copies have been distributed pursuant to the NEF - AXM) (Entered: 03/25/2008)

REPLY to Response to 63 MOTION to Compel Submission to Independent Mental Examination; Memorandum of Points and Authorities in Support Thereof ; filed by Defendant Consolidated Resorts. Reply in Support of Motion to Compel Submission to Independent Mental Examination (Attachments: # 1 Declaration of Joann Behrman-Lippert, PH.D.)(Taylor, Karyn) (Entered: 03/27/2008)

MINUTES OF PROCEEDINGS - Motion Hearing held on 4/3/2008 before Magistrate Judge George Foley, Jr. Crtrm Administrator: Donna Smith; Pla Counsel: Dana Johnson; Def Counsel: Karyn Taylor; FTR #: 9:20:59-10:04:45; Time of Hearing: 9:30 a.m.; Courtroom: 3A; The Court has reviewed the motion and briefs. The Court hears the representations of counsel. The 63 MOTION to Compel Submission to Independent Mental Examination STANDS SUBMITTED. The Court will issue a written decision. If the Court orders Plaintiff to undergo a mental examination it will be under the terms and conditions as stated on the record. (Copies have been distributed pursuant to the NEF - DES) (Entered: 04/03/2008)

ORDER Denying 63 Motion to Compel. Signed by Magistrate Judge George W Foley, Jr on 4/7/08. (Copies have been distributed pursuant to the NEF - AXM)

TRANSCRIPT of Proceedings: 72, Motion Hearing, held on 04/03/2008 before Judge George W. Foley, Jr. FTR Recording. Transcript prepared by Exceptional Reporting Services, Inc. (no image attached) (ABC) (Entered: 05/08/2008)

ORDER: Parties shall file an Interim Status Report which fully complies with LR 26-3 by 7/10/2008. Signed by Magistrate Judge George W Foley, Jr on 06/30/08. (Copies have been distributed pursuant to the NEF - SRK) (Entered: 06/30/2008)

Joint STATUS REPORT by Plaintiff U.S. Equal Employment Opportunity Commission. (Johnson, Dana) (Entered: 07/10/2008)

STIPULATION of Dismissal [Proposed] Consent Decree by Defendant Consolidated Resorts. (Attachments: # 1 Exhibit A)(Taylor, Karyn) (Entered: 10/07/2008)

CONSENT JUDGMENT in favor of Consolidated Resorts against U.S. Equal Employment Opportunity Commission. Court shall retain jurisdiction for the term of the Decree. Signed by Judge Lloyd D. George on 10/14/08. (Copies have been distributed pursuant to the NEF - OXC) (Entered: 10/16/2008)