Case: EEOC v. REKREM, INC. d/b/a WHOLE FOODS OF SOHO

Equal Employment v. Rekrem, Inc.

EEOC v. REKREM, INC., d/b/a Whole Foods of Soho

EEOC and Tazul v. REKREM, Inc. d/b/a Whole Foods in Soho et al.

EEOC v. REKREM, INC., d/b/a Whole Foods of Soho

No Court

Carly Knight, Frank Dobbin, Alexandra Kalev

COMPLAINT filed. Summons issued and Notice pursuant to 28 U.S.C. 636(c). (em) (Entered: 09/26/2000)

Magistrate Judge Frank Maas is so Designated. (em) (Entered: 09/26/2000)

Notice of reassignment to Judge Constance B. Motley . Copy of notice and judge's rules mailed to Attorney(s) of record: Michael J. O'Brien, Elizabeth Grossman, Katherine E. Bissell . (jp) (Entered: 11/01/2000)

ORDER; parties in this matter are hereby notified that a pre-trial conf. shall be held on 11/27/00 at 10:00 a.m. in Courtroom 26-A in the U.S. Courthouse at 500 Pearl Street ; ( signed by Judge Constance B. Motley ); Copies mailed. (lf) (Entered: 11/03/2000)

NOTICE OF MOTION by Nipu Tazul, Ali Dahhan, Shiek Ahmed, Amhad Eldin Abdou, Rifat Sharmin, Mohammad Ali, Hoshneara Begum, Mohammed Abu Sayed, Malik Issaen, Shoakat Ahmed to intervene by Nipu Tazul, Ali Dahhan, Shiek Ahmed, Amhad Eldin Abdou, Rifat Sharmin, Mohammad Ali, Hoshneara Begum, Mohammed Abu Sayed, Malik Issaen, Shoakat Ahmed . Return date 11/28/00. (rag) (Entered: 11/21/2000)

MEMORANDUM OF LAW by Nipu Tazul, Ali Dahhan, Shiek Ahmed, Amhad Eldin Abdou, Rifat Sharmin, Mohammad Ali, Hoshneara Begum, Mohammed Abu Sayed, Malik Issaen, Shoakat Ahmed in support of [4-1] motion to intervene by Nipu Tazul, Ali Dahhan, Shiek Ahmed, Amhad Eldin Abdou, Rifat Sharmin, Mohammad Ali, Hoshneara Begum, Mohammed Abu Sayed, Malik Issaen, Shoakat Ahmed . (rag) (Entered: 11/21/2000)

PRE-TRIAL SCHEDULE AND ORDER: All discovery shall be concluded by all parties by 5/21/01. Each party's pre-trial memorandum and a joint pre-trial order must be submitted by 6/12/01. The next pre-trial conference shall be held in Room 26A at 10:00 AM on 4/10/01, at which time all pending motions and all pre-trial discovery matters will be heard. The trial will commence on 6/18/01 at 10:00 AM, preceding which there will be a final pre-trial conference in Room 26A. The parties are to meet on or before 2/21/01 and exchange all documents, of any description, relevant to this case. On 3/21/01, the parties are to meet and prepare a schedule of all depositions to be taken during the period 4/2/01 to 4/13/01. A copy of the schedule shall be sent to the Court. There will be no extensions of time granted as to this schedule. All motions to intervene must be filed by 1/8/01. Answers to said motions shall be filed by 1/29/01. Replies are to be filed by 2/12/01. The motions will then be taken on submission. There will be no extensions of time granted. ( signed by Judge Constance B. Motley ); Copies mailed. (sn) Modified on 12/01/2000 (Entered: 12/01/2000)

NOTICE OF MOTION by Saila Sultana; for an Order, purs. to FRCP 24(a) and 42 U.S.C. 2000e-5(f)(1), granting Saila Sultana leave to intervene as of right in this action ; Return date not indicated. Affirmation of Michael B. Lumer in support of motion attached. Received in night deposit on 1/8/01 at 7:21 p.m. (jp) (Entered: 01/09/2001)

MEMORANDUM OF LAW by Saila Sultana in support of [7-1] motion for an Order, purs. to FRCP 24(a) and 42 U.S.C. 2000e-5(f)(1), granting Saila Sultana leave to intervene as of right in this action. Received in night deposit on 1/8/01 at 7:21 p.m. (jp) (Entered: 01/09/2001)

ANSWER to Complaint by Rekrem, Inc. (Attorney Scott T. Baken from the Firm: Jackson Lewis Schnitzler & Krupman) (filed in night deposit on 1/22/01 @6:14pm) (lam) (Entered: 01/24/2001)

RULE 1.9 CERTIFICATE filed by Rekrem, Inc. (lam) (Entered: 01/24/2001)

MEMORANDUM OF LAW by Rekrem, Inc. in opposition to [4-1] motion to intervene by Nipu Tazul, Ali Dahhan, Shiek Ahmed, Amhad Eldin Abdou, Rifat Sharmin, Mohammad Ali, Hoshneara Begum, Mohammed Abu Sayed, Malik Issaen, Shoakat Ahmed; [7-1] motion for an Order, purs. to FRCP 24(a) and 42 U.S.C. 2000e-5(f)(1), granting Saila Sultana leave to intervene as of right in this action. (Rec'd in night deposit box 1/29/01 11:24 PM) (sn) (Entered: 01/31/2001)

MEMORANDUM OF LAW by Saila Sultana in further support of [7-1] motion for an Order, purs. to FRCP 24(a) and 42 U.S.C. 2000e-5(f)(1), granting Saila Sultana leave to intervene as of right in this action . (djc) (Entered: 02/14/2001)

AFFIRMATION of Michael B. Lumer by Saila Sultana in Further Support of [7-1] motion for an Order, purs. to FRCP 24(a) and 42 U.S.C. 2000e-5(f)(1), granting Saila Sultana leave to intervene as of right in this action . (djc) (Entered: 02/14/2001)

STIPULATION and ORDER, substituting Dorsey & Whitney LLP in place of Jackson Lewis Schnitzler & Krupman as counsel for defendant Rekrem, Inc., d/b/a Whole Foods of Soho . ( signed by Judge Constance B. Motley ) (kw) (Entered: 04/05/2001)

REVISED PRE-TRIAL SCHEDULE AND ORDER: all discovery shall be concluded by all parties no later than 6/22/01; each party's pre-trial memorandum and a joint pre-trial order must be submitted by 7/13/01; the next pre-trial conference shall be held in Room 26A on 5/8/01 at 11:00 a.m., at which time all pending motions and all pre-trial discovery matters will be heard; the trial will commence on 6/18/01 at 10:00 a.m., preceding which there will be a final pre-trial conference in Room 26A; on 3/21/01, the parties exchanged lists of depositions to be taken. The parties will meet and prepare a schedule of all depositions to be taken during the period 5/7/01 to 5/25/01. A copy of the schedule shall be sent to the Court. No interrogatories are to be served, except those seeking the location or identity of prospective witnesses or depoenents. There will be no further extensions of time granted as to this schedule. ( signed by Judge Constance B. Motley ); Copies mailed. (sac) (Entered: 04/05/2001)

MEMORANDUM OPINION AND ORDER #85425, granting [4-1] motion to intervene by Nipu Tazul, Ali Dahhan, Shiek Ahmed, Amhad Eldin Abdou, Rifat Sharmin, Mohammad Ali, Hoshneara Begum, Mohammed Abu Sayed, Malik Issaen, and Shoakat Ahmed; this court orders that the additional claims alleged in the proposed Tazul complaint be severed from the claims based upon Title VII ; dismissing [7-1] motion for leave to intervene by Saila Sultana, purs. to FRCP 24(a) and 42 U.S.C. 2000e-5(f)(1), as of right in this action and the Sultana proposed intervening complaint. ( signed by Judge Constance B. Motley ); Copies mailed. (kw) Modified on 05/07/2001 (Entered: 04/09/2001)

ORDER, the pretrial conference originally scheduled for 5/8/01 @11:00 a.m. is rescheduled for 5/8/01 @2:30 p.m., in courtroom 26A, 500 Pearl St., NY, NY... ( signed by Judge Constance B. Motley ) (kg) (Entered: 04/25/2001)

PRE-TRIAL SCHEDULE AND ORDER; joinder of other parties and amendments to pleadings must be completed by 6/8/01; all discovery shall be concluded by all parties no later than 1/5/02; each party's pre-trial memorandum and a joint pre-trial order must be submitted by 4/1/02; the next pre-trial conference shall be held in Room 26A on 10/4/01 at 10:00 a.m., at which time all pending motions and all pre-trial discovery matters will be heard; the trial will commence on 4/15/02 at 10:00 a.m., preceding which there will be a final pre-trial conference in Room 26A; the parties are to meet on or before 6/8/01 and exchange all documents, of any description, relevant to this case. Sanctions will be imposed for failure to produce any relevant document; thereafter, on 8/17/01, the parties are to meet and prepare a schedule of all depositions to be taken during the period 9/5/01 to 11/5/01. Documents relating to advise of counsel defense are to be produced by 6/29/01. ( signed by Judge Constance B. Motley ); Copies mailed. (sac) (Entered: 05/09/2001)

NOTICE OF MOTION by Jackson Lewis Schnitzler & Krupman; for an order to quash Subpoenas Duces Tecum pursaunt to Rules 45(c)(3)(A)(iii) and 45(c)(3)(A)(iv) of the F.R.C.P. and the Local Rules of this Court ; Return date: not indicated. (pl) (Entered: 09/20/2001)

AFFIDAVIT of Scott T. Baken, Esq. in support of [21-1] motion for an order to quash Subpoenas Duces Tecum pursaunt to Rules 45(c)(3)(A)(iii) and 45(c)(3)(A)(iv) of the F.R.C.P. and the Local Rules of this Court . (pl) (Entered: 09/20/2001)

MEMORANDUM OF LAW in support of [21-1] motion for an order to quash Subpoenas Duces Tecum pursaunt to Rules 45(c)(3)(A)(iii) and 45(c)(3)(A)(iv) of the F.R.C.P. and the Local Rules of this Court. (pl) (Entered: 09/20/2001)

AFFIDAVIT of Scott T. Baken, Esq. in support of [21-1] motion for an order to quash Subpoenas Duces Tecum pursuant to Rules 45(c)(3)(A)(iii) and 45(c)(3)(A)(iv) of the F.R.C.P. and the Local Rules of this Court . (pl) (Entered: 09/20/2001)

ORDER; reset pre-trial conference for 2:00 10/29/01, Courtroom 26A . ( signed by Judge Constance B. Motley ); Copies mailed. (pl) (Entered: 10/01/2001)

PRE-TRIAL SCHEDULE & ORDER: Pretrial conference set for 2:30 12/14/01; The trial will commmence on 4/15/02, at 10:00 am; on 2/14/02, the parties are to meet and prepare a schedule of all depositions to be taken during the period 2/25/02 to 3/29/02; Opposition to motion to quash due 11/16/01 and reply by 11/26/01 ( signed by Judge Constance B. Motley ); Copies mailed. (cd) (Entered: 11/01/2001)

Deadline(s) updated: Response to motion reset to 11/16/01 for [21-1] motion for an order to quash Subpoenas Duces Tecum pursaunt to Rules 45(c)(3)(A)(iii) and 45(c)(3)(A)(iv) of the F.R.C.P. and the Local Rules of this Court ; Reply to Response to Motion reset to 11/26/01 for [21-1] motion for an order to quash Subpoenas Duces Tecum pursaunt to Rules 45(c)(3)(A)(iii) and 45(c)(3)(A)(iv) of the F.R.C.P. and the Local Rules of this Court . (cd) (Entered: 11/01/2001)

NOTICE of Change of Address by Equal Employment (indicated on the system) (cd) (Entered: 11/08/2001)

BRIEF by Equal Employment re: in Opposition to Jackson Lewis Schnitzler & Krupman's Motion to Quash the EEOC's Subpoenas Duces Tecum. (djc) (Entered: 11/27/2001)

AFFIDAVIT of Michael J. O'Brien by Equal Employment in support of Subpoena Duces Tecum. (djc) (Entered: 11/27/2001)

BRIEF by Equal Employment in Opposition to [21-1] motion for an order to quash Subpoenas Duces Tecum pursaunt to Rules 45(c)(3)(A)(iii) and 45(c)(3)(A)(iv) of the F.R.C.P. and Local Rules of this Court. (djc) (Entered: 11/27/2001)

REPLY MEMORANDUM of Law in support of Jackson Lewis Schnitzer & Krupman's [21-1] motion for an order to quash Subpoenas Duces Tecum pursaunt to Rules 45(c)(3)(A)(iii) and 45(c)(3)(A)(iv) of the F.R.C.P. and the Local Rules of this Court (db) (Entered: 12/06/2001)

NOTICE OF MOTION by Equal Employment; for leave to file a Brief in Response to JLSK's Reply Papers on its Motion to Quash the EEOC's Subpoena Duces Tecum to Three of its Attorneys ; Return date not indicated. (djc) (Entered: 01/07/2002)

RESPONSE BRIEF by Equal Employment in Opposition to [21-1] motion for an order to quash Subpoenas Duces Tecum pursaunt to Rules 45(c)(3)(A)(iii) and 45(c)(3)(A)(iv) of the F.R.C.P. and Local Rules of this Court (djc) (Entered: 01/09/2002)

SUPPLEMENTAL TRANSMITTAL AFFIDAVIT of Michael J.O'Brien by Equal Employment Re: [34-1] opposition response . (djc) (Entered: 01/09/2002)

MEMORANDUM OPINION AND ORDER #86444, granting in part, and denying in part [21-1] motion for an order to quash Subpoenas Duces Tecum pursaunt to Rules 45(c)(3)(A)(iii) and 45(c)(3)(A)(iv) of the F.R.C.P. and the Local Rules of this Court; JLSK shall produce documents in response EEOC requests Nos. 1-4 by 1/18/02 . ( signed by Judge Constance B. Motley ); Copies mailed. (kw) (Entered: 01/14/2002)

ORDER, deft's former counsel shall comply with the court's 1/8 order and produce the documents in question by 2/22/02 ; depositions shall be taken between 3/25/02 and 5/2/02 ; dispositive motions filing deadline for 7/12/02 ; the trial in this matter, if any, shall commence on 9/10/02 ( signed by Judge Constance B. Motley ); Copies mailed. (cd) (Entered: 01/15/2002)

CONSENT DECREE (JUDGMENT): resolving all claims arising out of the issues between the EEOC, Intervenors, and Rekrem, Inc. in this lawsuit, including, w/out limitations, back, pay, front pay, compensatory and punitive damages, injunctive relief, costs, and attorneys' fees; in settlement of this dispute, Rekrem LLC shall pay to the order of the Intervenors and their attorneys a total of $715,000.00 (see consent judgment for the break down of the payments); each of the parties to this Decree shall bear their respective attorneys' fees and costs;. ( signed by Judge Constance B. Motley ) Entered On Docket: 3/15/02. (ae) (Entered: 03/15/2002)

Case closed. (ae) (Entered: 03/15/2002)