Case: EEOC v. Go Daddy Software Inc

EEOC v. Go Daddy Software, Inc.

EEOC v. Go Daddy Software, Inc.

EEOC v. Go Daddy Software, Inc.

EEOC v. Go Daddy Software, Inc.

Equal Employment Opportunity Commission v. Go Daddy Software, Inc.

U.S. Court of Appeals for the Ninth Circuit

William R. Tamayo

Carly Knight, Frank Dobbin, Alexandra Kalev

COMPLAINT FILED (JIR) (Entered: 10/01/2004)

ORDER by Judge David G. Campbell Pla shall effect service of the complaint and summons on all dfts within 120 days after the filing of the complaint. Initial order shall serve as notice to pla under Rule 4(m) that the Court may dismiss this action without further notice with respect to any dft(s) named in the complaint that are not served accomplished on dft(s) in accordance with Rule 4 and shall request Court set a Case Management Conference. Pla(s) shall provide notification to the Court within 10 days after service of the complaint on all dft(s). Upon receipt of such notice, Court will issue an order setting Rule 16 Case Management Conference that directs parties to comply with Rule 26(f) of the Fed Rules of Cv Procedure and describes the Case Management Report that must be filed by parties before the Case Management Conference. As stated in Rule 16(d), parties shall not seek disc from any source until they have conferred as required by Rule 26(f). Pla(s) shall ensure that all dft(s) promptly receive a copy of this order.(cc: all counsel) re: order filed [2−1] (DMT) (ADI−ICMS, ). (Entered: 10/06/2004)

RETURN OF SERVICE EXECUTED summons/complaint upon Stat Agent Mike Grill for dft Go Daddy Software on 9/30/04 (KCS) Modified on 10/26/2004 (Entered: 10/25/2004)

NOTICE by pla EEOC of service of summons, complaint and initial order on 10/18/04 upon Go Daddy Software, Inc. (KCS) (Entered: 11/01/2004)

CORPORATE DISCLOSURE STATEMENT by dft (DMT) (Entered: 12/16/2004)

ANSWER to complaint [1−1] by dft (DMT) (Entered: 12/16/2004)

ORDER by Judge David G. Campbell ; prel scheduling conf set for 10:00 2/10/05 (cc: all counsel) (DMT) (ADI−ICMS, ). (Entered: 12/29/2004)

CASE MGT REPORT: ; ; (FMP) (Entered: 02/04/2005)

MINUTE ENTRY before Judge David G. Campbell. Crt Rptr: Patricia Lyons. Appearances: P. David Lopez for pla; Robert Oller for dft. Preliminary scheduling conference held. Dispositive motions due 1/19/06. Order to follow. [cc: DGC] [9−2] (LMR) (Entered: 02/11/2005)

ORDER by Judge David G. Campbell ; discovery ddl set for 11/18/05 ; dispositive motions due 1/19/06 (cc: all counsel) (DMT) (ADI−ICMS, ). (Entered: 02/17/2005)

NOTICE of service of discovery by dft. (DMT) (Entered: 03/01/2005)

NOTICE of compliance of initial disclosure statement pursuant to FRCivP 26(a) by pla EEOC (MAP) (Entered: 03/08/2005)

ATTORNEY APPEARANCE for pla EEOC by Lucila G Rosas (FMP) (Entered: 03/16/2005)

NOTICE of Service of Discovery Responses to Defendant by pla. (SAT) (Entered: 04/14/2005)

NOTICE of service of discovery by pla. (DMT) (Entered: 05/10/2005)

NOTICE by pla OF TAKING DEPO OF representative of Go Daddy Software Inc on the following date(s): 6/14/05 (DMT) (Entered: 05/10/2005)

NOTICE of service of discovery by pla. (DMT) (Entered: 05/10/2005)

NOTICE of service of discovery by pla EEOC. (KMG) (Entered: 05/11/2005)

NOTICE of service of discovery by dft Go Daddy Software . (SRB) (Entered: 06/09/2005)

NOTICE of service of discovery by dft. (CMM) (Entered: 06/14/2005)

NOTICE of service of discovery by pla EEOC . (MAP) (Entered: 06/15/2005)

NOTICE of service of discovery by dft Go Daddy Software . (KCS) (Entered: 06/15/2005)

NOTICE by pla OF TAKING DEPO OF Craig Franklin on the following date(s): 7/7/05 (SAT) (Entered: 06/15/2005)

NOTICE (Amended) by pla EEOC OF TAKING DEPO OF Go Daddy Software, Inc. on the following date(s): 07/08/05 @ 9:00 a.m. (KCS) (Entered: 06/28/2005)

ORDER by Judge David G. Campbell that 1. On or before 7/1/05, counsel for pla shall seek to obtain from their client additional information regrding the doctors in Marakesh, Morocco, and Columbus, Ohio, and shall provide such information to dft in writing. 2. On or before 7/1/05, pla shall provide dft with releases authorizing past employers to release employment records to dft; 3. The Court declined to order Plaintiff to provide a release relating to educational institutions, as this information has not been sought in a formal discovery request by Pla; 4. In connection with these rulings, the Court concluded that past educational and employment records, including those before 2001, are relevant for purposes of discovery. This ruling shall have no effect on the Court's determination of relevancy at trial or in motions for summary judgment (cc: all counsel) re: order filed [26−1] (SAT) (ADI−ICMS, ). (Entered: 06/29/2005)

Notice of service of defendant's second request for production of documents by Go Daddy Software, Inc. (RDS) (Entered: 07/08/2005)

Notice of Service of Defendant's First Supplemental Disclosure Statement by Go Daddy Software, Inc. (RDS) (Entered: 07/11/2005)

Notice of service of discovery responses by Equal Employment Opportunity Commission. (KCS) (Entered: 07/21/2005)

Notice of Service of Defendant's Second Supplemental Disclosure Statement, by Go Daddy Software, Inc. (RDS) (Entered: 07/26/2005)

Notice re Service of Discovery Responses by Equal Employment Opportunity Commission (Rosas, Lucila) (Entered: 08/08/2005)

Notice re Plaintiff's Third Supplemental Rule 26(a)(1) Disclosure Statement by Equal Employment Opportunity Commission (Rosas, Lucila) (Entered: 09/14/2005)

Notice re Plaintiff's Fourth Supplemental Disclosure by Equal Employment Opportunity Commission (Lopez, P) (Entered: 09/15/2005)

NOTICE of Deposition of Craig Franklin Amended, filed by Equal Employment Opportunity Commission. (Rosas, Lucila) (Entered: 09/21/2005)

NOTICE of Deposition of Brett Villeneuve, filed by Equal Employment Opportunity Commission. (Rosas, Lucila) (Entered: 09/21/2005)

NOTICE of Deposition of Heather Slezak, filed by Equal Employment Opportunity Commission. (Rosas, Lucila) (Entered: 09/21/2005)

ORDER re discovery conference call. Signed by Judge David G Campbell on 9/22/05. (DGC, ) (Entered: 09/22/2005)

Notice re Service of Def's Third RFP, Third Suppl Discl Stmt, First Suppl Resp RFP by Go Daddy Software, Inc. (Oller, Robert) (Entered: 09/27/2005)

Notice re Service of Discovery Requests to Defendant by Equal Employment Opportunity Commission (Lopez, P) (Entered: 09/28/2005)

NOTICE of Deposition of Yolanda Morgan, filed by Equal Employment Opportunity Commission. (Rosas, Lucila) (Entered: 10/06/2005)

NOTICE of Deposition of Barbara Rechterman, filed by Equal Employment Opportunity Commission. (Rosas, Lucila) (Entered: 10/06/2005)

NOTICE of Deposition of Robert Parsons, filed by Equal Employment Opportunity Commission. (Rosas, Lucila) (Entered: 10/06/2005)

NOTICE of Deposition of Angel MacNevin, filed by Equal Employment Opportunity Commission. (Rosas, Lucila) (Entered: 10/06/2005)

NOTICE of Deposition of Tyler Wirtjes, filed by Equal Employment Opportunity Commission. (Rosas, Lucila) (Entered: 10/06/2005)

Notice re Service of Defendant's Fourth Supplemental Disclosure Statement by Go Daddy Software, Inc. (Oller, Robert) (Entered: 10/11/2005)

Notice re Notice of Service by Go Daddy Software, Inc. of Defendant's Fourth Supplemental Response to Plaintiff EEOC's First Request for Production of Documents and Fifth Supplemental Disclosure Statement (Oller, Robert) (Entered: 10/17/2005)

Notice re Notice of Service of Defendant's Third Supplemental Response to Plaintiff EEOC's First Request for Production of Documents and Sixth Supplemental Disclosure Statement by Go Daddy Software, Inc. (Oller, Robert) (Entered: 10/18/2005)

NOTICE of Deposition of Robert Parsons, filed by Equal Employment Opportunity Commission. (Rosas, Lucila) (Entered: 10/19/2005)

Notice re Service of Plaintiff's Fifth Supplemental Rule 26(a) (1) Disclosure Statement by Equal Employment Opportunity Commission (Rosas, Lucila) (Entered: 10/19/2005)

Notice re Service of Defendant's Fifth Supplemental Response to Plaintiff EEOC's First Request for Production of Documents by Go Daddy Software, Inc. (Oller, Robert) (Entered: 10/20/2005)

ORDER re 10/20/05 discovery conference call. Signed by Judge David G Campbell on 10/24/05. (DGC, )

NOTICE of Deposition of Adrian Quinton, filed by Equal Employment Opportunity Commission. (Rosas, Lucila) (Entered: 10/27/2005)

NOTICE of Deposition of Craig Franklin (Second Amended), filed by Equal Employment Opportunity Commission. (Rosas, Lucila) (Entered: 10/27/2005)

NOTICE of Deposition of Jackie Baumgartner, filed by Equal Employment Opportunity Commission. (Rosas, Lucila) (Entered: 10/27/2005)

NOTICE of Deposition of Christine Jones, filed by Equal Employment Opportunity Commission. (Rosas, Lucila) (Entered: 10/27/2005)

NOTICE of Deposition of Wendell Scott Brown, filed by Go Daddy Software, Inc.. (Oller, Robert) (Entered: 10/28/2005)

NOTICE of Deposition of Sean Dunham, filed by Go Daddy Software, Inc.. (Oller, Robert) (Entered: 10/28/2005)

NOTICE of Deposition of Maria Rojas, filed by Go Daddy Software, Inc.. (Oller, Robert) (Entered: 10/28/2005)

Notice re Service of Defendant's Discovery Responses by Go Daddy Software, Inc. (Oller, Robert) (Entered: 10/28/2005)

Notice re Discovery Responses to Defendant (Third Request for Documents) by Equal Employment Opportunity Commission (Lopez, P) (Entered: 11/01/2005)

ORDER re discovery conference call. Signed by Judge David G Campbell on 11/2/05. (DGC, )

Notice re Service of Defendant's Seventh Supplemental Disclosure Statement by Go Daddy Software, Inc. (Oller, Robert) (Entered: 11/02/2005)

Notice re Service of Sixth Supplemental Rule 26(a)(1) Disclosure Statement by Equal Employment Opportunity Commission (Rosas, Lucila) (Entered: 11/03/2005)

ORDER re discovery conference call. Signed by Judge David G Campbell on 11/4/05. (DGC, )

Notice re Service of Defendant's Eighth Supplemental Disclosure Statement by Go Daddy Software, Inc. (Oller, Robert) (Entered: 11/10/2005)

Notice re Service of Defendant's Ninth Supplemental Disclosure Statement by Go Daddy Software, Inc. (Oller, Robert) (Entered: 11/10/2005)

Notice re Service of Defendant's Amended Third Supplemental Disclosure Statement by Go Daddy Software, Inc. (Oller, Robert) (Entered: 11/15/2005)

Notice re Service of Discovery Responses to Defendant by Equal Employment Opportunity Commission (Lopez, P) (Entered: 11/17/2005)

ORDER granting 66 STIPULATION Re: Confidentiality Order by Go Daddy Software, Inc. (Oller, Robert) filed by Go Daddy Software, Inc . Signed by Judge David G Campbell on 11/17/05. (LSP) (Entered: 11/18/2005)

NOTICE of Deposition of Adriana Parsons, filed by Equal Employment Opportunity Commission. (Rosas, Lucila) Modified on 11/22/2005 (LSP). DOCUMENT IS UNSIGNED, ATTORENY NOTICED TO REFILE. (Entered: 11/21/2005)

NOTICE of Deposition of Robert Parsons (Third Amended), filed by Equal Employment Opportunity Commission. (Rosas, Lucila) (Entered: 11/21/2005)

NOTICE of Deposition of Christine Jones (First Amended), filed by Equal Employment Opportunity Commission. (Rosas, Lucila) (Entered: 11/21/2005)

NOTICE TO FILER OF DEFICIENCY re 72 Notice of Deposition filed by Equal Employment Opportunity Commission. Description of deficiency: Docuemnt does not contain a signature. (LSP) (Entered: 11/22/2005)

NOTICE of Deposition of Adriana Parsons Amended, filed by Equal Employment Opportunity Commission. (Rosas, Lucila) (Entered: 11/22/2005)

NOTICE of Deposition of Wayne DeStefano, filed by Go Daddy Software, Inc.. (Oller, Robert) (Entered: 11/28/2005)

NOTICE of Deposition of Shane Blanton, filed by Go Daddy Software, Inc.. (Oller, Robert) (Entered: 11/28/2005)

NOTICE of Deposition of Brad Kline, filed by Go Daddy Software, Inc.. (Oller, Robert) (Entered: 11/28/2005)

NOTICE of Deposition of Adriana Parsons (Second Amended), filed by Equal Employment Opportunity Commission. (Rosas, Lucila) (Entered: 12/06/2005)

NOTICE of Deposition of Jennifer Davis, filed by Equal Employment Opportunity Commission. (Rosas, Lucila) (Entered: 12/06/2005)

NOTICE of Deposition of Jason Krumpelman, filed by Go Daddy Software, Inc.. (Oller, Robert) (Entered: 12/07/2005)

NOTICE of Deposition of Shane Blanton, filed by Go Daddy Software, Inc.. (Oller, Robert) (Entered: 12/07/2005)

NOTICE of Deposition of Amber White, filed by Equal Employment Opportunity Commission. (Rosas, Lucila) (Entered: 12/07/2005)

Notice re Service of Defendant's Tenth Supplemental Disclosure Statement by Go Daddy Software, Inc. (Oller, Robert) (Entered: 12/08/2005)

Notice re Service of Defendant's Fourth Supplemental Response to Plaintiff's First Request for Production of Documents by Go Daddy Software, Inc. (Oller, Robert) (Entered: 12/08/2005)

NOTICE of Deposition of Jennifer Davis (Amended), filed by Equal Employment Opportunity Commission. (Lopez, P) (Entered: 12/09/2005)

Notice re Service of Eighth Supplemental Disclosure Statement by Equal Employment Opportunity Commission (Lopez, P) (Entered: 12/09/2005)

Notice re Service of Ninth Supplemental Disclosure Statement by Equal Employment Opportunity Commission (Lopez, P) (Entered: 12/14/2005)

NOTICE of Deposition of Amber White (First Amended), filed by Equal Employment Opportunity Commission. (Rosas, Lucila) (Entered: 12/20/2005)

Notice re Service of Tenth Supplemental Disclosure Statement by Equal Employment Opportunity Commission (Lopez, P) (Entered: 12/20/2005)

Notice re Service of Defendant's Fifth Supplemental Response to Plaintiff EEOC's First Request for Production of Documents by Go Daddy Software, Inc. (Oller, Robert) (Entered: 01/03/2006)

MOTION for Summary Judgment by Go Daddy Software, Inc.. (Oller, Robert) (Entered: 01/19/2006)

STATEMENT of of Facts in Support of Defendant's Motion for Summary Judgment re 94 MOTION for Summary Judgment by Defendant Go Daddy Software, Inc.. (Attachments: # 1 # 2 Exhibit Exhibit A (part 2 of 3)# 3 Exhibit Exhibit A (part 3 of 3)# 4 Exhibit Exhibit B# 5 Exhibit Exhibit C# 6 Exhibit Exhibit D# 7 Exhibit Exhibit E# 8 Exhibit Exhibit F# 9 Exhibit Exhibit G# 10 Exhibit Exhibit H)(Oller, Robert) (Entered: 01/19/2006)

MOTION to Amend/Correct 1 Complaint by Equal Employment Opportunity Commission. (Attachments: # 1 Exhibits A − E)(Rosas, Lucila) (Entered: 01/19/2006)

MOTION for Partial Summary Judgment violation of record keeping, statute of limitations and exhaustion of administrative remedies by Equal Employment Opportunity Commission. (Lopez, P) (Entered: 01/19/2006)

STATEMENT of of Facts in Support of Its Motion for Partial Summary Judgment re 97 MOTION for Partial Summary Judgment violation of record keeping, statute of limitations and exhaustion of administrative remedies by Plaintiff Equal Employment Opportunity Commission. (Attachments: # 1 Exhibits A − D# 2 Exhibits E − L)(Lopez, P) (Entered: 01/19/2006)

ERRATA re 98 Statement, Facts in Support of Motion for Partial Summary Judgment by Plaintiff Equal Employment Opportunity Commission. (Attachments: # 1 Statement of Facts in Support of Motion for Partial Summary Judgment# 2 Exhibits A − D# 3 Exhibits E − L)(Lopez, P) (Entered: 01/20/2006)

RESPONSE in Opposition re 96 MOTION to Amend/Correct 1 Complaint filed by Go Daddy Software, Inc.. (Oller, Robert) (Entered: 02/03/2006)

Exhibit List in Support of Opposition to Plaintiff EEOC's Motion for Leave to Amend Complaint by Go Daddy Software, Inc... (Oller, Robert) (Entered: 02/06/2006)

REPLY to Response to Motion re 96 MOTION to Amend/Correct 1 Complaint filed by Equal Employment Opportunity Commission. (Attachments: # 1 Exhibits A − O)(Rosas, Lucila) (Entered: 02/13/2006)

Notice re Filing of Original Signed Declaration of Youssef Bouamama by Equal Employment Opportunity Commission re 102 Reply to Response to Motion (Attachments: # 1 Declaration of Youssef Bouamama)(Rosas, Lucila) (Entered: 02/17/2006)

Notice re Service of First Supplemental Response to 30(b)(5) Request for Production of Documents by Go Daddy Software, Inc. (Oller, Robert) (Entered: 02/21/2006)