Case: EEOC v. Carrols Corporation

Equal Employment v. Carrols Corporation

Equal Employment v. Carrols Corporation

Equal Employment v. Carrols Corporation

Equal Employment v. Carrols Corporation

Carly Knight, Frank Dobbin, Alexandra Kalev

COMPLAINT filed; ; Service deadline 1/16/99 for Carrols Corporation (tad) (mc, ). (Entered: 11/17/1998)

Filing Order Issued; Conference set before Magistrate Judge Gary L. Sharpe in Syracuse, (tad)

G.O. 25 Filing Order

SUMMONS(ES) issued for Carrols Corporation (tad)

Summons Issued

ANSWER & AFFIRMATIVE DEFENSES: to Complaint by Carrols Corporation (Attorney Jack D. Eisenberg) (jmb) (mc, ). (Entered: 01/27/1999)

Joint request by parties to adjourn the Rule 16 conference currently scheduled for 3/17/99 before Mag. Judge Sharpe; Proposed order attached. (drm) (mc, ). (Entered: 03/09/1999)

Scheduling Notice:, reset Filing Order Deadlines: Telephone Conference set before Magistrate Judge Gary L. Sharpe in Syracuse, Status Conference at 11:00 4/21/99, Deadline for filing Case Management Plan, 4/12/99 (drm) (mc, ). (Entered: 03/09/1999)

Proposed Joint Civil Case Management Plan Submitted. (jmb) (mc, ). (Entered: 04/12/1999)

Letter from attorney William Kandel on behalf of defendant dated 4/9/99 requesting that the rule 16 conference be conducted in person on 4/21/99; Forwarded to GLS for review (drm) (mc, ). (Entered: 04/16/1999)

Docket Annotation

Attorney Kandel will appear in person for rule 16 conference on 4/21/99 at 11:00 A.M.; Attorney Barkey will appear by telephone for the conference. (drm)

Minute entry: Telephone/In Person Rule 16 conference held before Mag. Judge Sharpe; App: David Barkey, Esq. and Elizabeth Grossman, Esq. for plaintiffs by telephone; William Kandell, Esq., William Sardella, Esq., and Joseph Zirkman, Esq. for defendant in person; Parties discuss phased discovery with parties; Mag. Judge Sharpe deems this a complex case and orders ALL WRITTEN DISCOVERY completed by 9/21/99; Mag. Judge Sharpe refuses to limit the scope of written discovery to one single issue; Parties are advised of discovery dispute resolution policies; Defendants directed to file a substitution of attorney; Written order to be issued; 11:00 - 11:45 A.M. (drm) (mc, ). (Entered: 04/25/1999)

DISCOVERY ORDER: all written discovery in this matter is to be completed on or before reset Discovery deadline to 9/21/99 ; Service of discovery requests must be made a sufficient number of days beofre this deadine to allow responses to be served before the cut off. (Signed by Magistrate Judge Gary L. Sharpe) (jmb) (mc, ). (Entered: 04/27/1999)

NOTICE of attorney appearance as co-counsel for Carrols Corporation by William L. Kandel and Aimee B. Meltzer; with Affidavit of Service by Federal Express attached. (smo) (mc, ). (Entered: 08/09/1999)

Letter from attorney William Kandel dated 8/10/99 requesting an extension of the UPSO in this case; EEOC does not consent to such request; Correspondence attached. (drm) (mc, ). (Entered: 08/17/1999)

Discovery ORDER: that all WRITTEN Discovery in this matter is to be completed by Reset Discovery deadline to 2/21/00 ; Service of discovery requests must be made a sufficient number of days before this deadline to allow responses to be served before the cut-off; Please refer to Local Rule 16.2 (Discovery Cut-Off) (Signed by Magistrate Judge Gary L. Sharpe) (smo) (mc, ). (Entered: 08/23/1999)

Letter dated 1/20/00 by David Barkey, Esq. requesting a three month extension for written discovery (smo) (mc, ). (Entered: 01/25/2000)

REQUEST and ORDER dated 1/26/00 to extend deadline for written discovery; ORDERED that ALL WRITTEN discovery in this matter is to be completed on or before 5/22; Reset Discovery deadline to 5/22/00 ; Service of Discovery requests must be made a sufficient number of days before this deadline to allow responses to be served before the cutt-off; please refer to Local Rule 16.2 (Signed by Magistrate Judge Gary L. Sharpe) (smo) (mc, ). (Entered: 01/31/2000)

Letter of attorney David Barkey dated 6/9/00 on behalf of plaintiff regarding outstanding discovery disputes between parties; Plaintiff is requesting the court's assistance in resolving these disputes. (drm) (mc, ). (Entered: 06/13/2000)

Letter of attorney William Kandel on behalf of defendants dated 6/12/00 in response to [14-1] letter of plaintiff's counsel regarding discovery problems. (drm) (mc, ). (Entered: 07/07/2000)

Docket Annotation

CRD Dan McAllister spoke with defendants' attorney William Kandel regarding [14-1] letter of plaintiff's attorney; Parties will attempt to resolve any part of the discovery dispute they can and then come back to the court with any remaining issues. (drm)

STIPULATED PROTECTIVE ORDER on behalf of Equal Employment, Carrols Corporation (signed by Magistrate Judge Gary L. Sharpe on 7/11/00). (cdl) (mc, ). (Entered: 07/20/2000)

Letter from attorney David Barkey dated 7/25/00 on behalf of plaintiff asking the court's assistance in resolving an outstanding discovery problem; Letters between parties attached (drm) (mc, ). (Entered: 07/31/2000)

Scheduling Notice: set Telephone Pretrial Conference for 10:00 8/9/00 before Mag. Judge Sharpe (drm) (mc, ). (Entered: 07/31/2000)

Minute entry of telephone conference before Mag. Judge Sharpe: App: David Barkey, Esq. and Elizabeth Grossman, Esq. for plaintiff; William Kandel, Esq. for defendant; Telephone conference regarding outstanding document requests made by plaintiff; Attorney Kandel advises the court that defendant will turn over the documents in question by 8/18/00; Parties to supply proposed order regarding this agreement; Attorney Kandel advises that defendant also has document requests that have gone unanswered by plaintiff; Parties will try to resolve this problem and if they are unable, they will come back to the court; 10:00 - 10:05 A.M. (drm) (mc, ). (Entered: 08/09/2000)

DISCOVERY ORDER: defendant, Carrols Corporation, shall produce to plaintiff, Equal Employment Opportunity Commission, the information and documents requested by the EEOC in its Sixth Set of Interrogatories and Sixth Request for Production of Documents, no later than August 18, 2000. (Signed by Magistrate Judge Gary L. Sharpe) (jmb) (mc, ). (Entered: 08/15/2000)

Letter application received from Carrols Corporation dated 3/2/01 by John D. Giansello, Esq., requesting: a discovery conference to resolve certain disputes over document requests, interrogatories and request for admissions propounded by Carrols that the parties have not been able to resolve completely through repeated conferences and negotiations; w/attachment and exhibits A through H. (jmb) (jmb, ). (Entered: 03/05/2001)

NOTICE/REQUEST: dated 3/9/01 by Suna P. Chandy, Esq., on behalf of Equal Employment, to Magistrate Judge Sharpe, stating that the parties have agreed to specific deadlines related to the discovery issues that remain, and jointly propose setting a discovery conference during the week of April 17-20, 2001. (jmb) (mc, ). (Entered: 03/15/2001)

Scheduling Notice: set Telephone Conference for 1:00 4/17/01 before MJ Sharpe (drm) (mc, ). (Entered: 03/26/2001)

Scheduling Notice: reset Pretrial Conference for 1:00 4/17/01 before MJ Sharpe Conference will be In Person pursuant to the request of the parties to personally appear terminated deadline for the telephone conference for 4/17/01 as it will now be in person (drm) (mc, ). (Entered: 03/30/2001)

LETTER RESPONSE: dated 4/6/01 by Michelle A. Caiola, Esq., on behalf of Equal Employment in opposition to [21-1] Letter Application by Carrols Corporation; and addressing the discovery disputes between the parties, w/attachment A. (jmb) (mc, ). (Entered: 04/10/2001)

LETTER RESPONSE of attorney John Giansello on behalf of Carrols Corporation dated 4/13/01 in opposition to [25-1] opposition response (drm) (mc, ). (Entered: 04/16/2001)

Minute entry of In Person conference before MJ Sharpe: App: Michelle Caiola, Esq., Sunu Chandy, Esq., & Elizabeth Grossman, Esq. for plaintiffs; John Giansello, Esq., Michael Delikat, Esq., & Joseph Zirkman, Esq. for defendants Mag. Judge Sharpe hears parties regarding discovery dispute that is currently pending between parties; Defendant will file its motion to compel discovery by 5/1/01 Plaintiff to respond by 5/22/01; Defendant to reply by 6/5/01; Motion will be taken on submit unless parties are otherwise notified. 1:00 - 2:25 p.m.; CD: 2001-061 (drm) Modified on 05/23/2001 (mc, ). (Entered: 04/19/2001)

Deadline updated; set Motion To Compel Filing deadline to 5/1/01, Response to Motion to compel by 5/22/01 Defendants may reply by 6/5/01 (drm)

Set Deadlines/Hearings

LETTER/REQUEST and ORDER dated 4/26/01; Letter addressed to Daniel R. Mcallister, Court Clerk for Magistrate Judge Sharpe, requesting that the Court reset the Discovery Motion Filing deadline to 5/3/01, Response to Motion to 5/24/01, and the Reply to Response deadline to 6/7/01; Request granted ( signed by Magistrate Judge Gary L. Sharpe on 4/27/01) (kcl) (mc, ). (Entered: 04/30/2001)

MOTION by John D. Giansello, Esq., on behalf of Carrols Corporation to Compel pltf to respond further to discovery requests with attached facts & certification of John D. Giansello; also attached letter of USEEOC and questionnare; Motion taken on submit before MJ Sharpe per [27-1] minute entry (fce) Modified on 05/04/2001 (rep, ). (Entered: 05/04/2001)

TRANSCRIPT filed of Status Conference before MJ Sharpe for dates of 4/17/01 (drm) (mc, ). (Entered: 05/23/2001)

RESPONSE MEMORANDUM and CROSS-MOTION by Michelle Caiola, Esq. for Plaintiff Equal Employment; Plaintiffs Cross-Motion requesting the Court to Compel Defendant to produce outstanding discovery, Attached Supporting Exhibits 1-5; Response in re: opposition to defendants [29-1] motion to Compel pltf to respond to discovery requests (kcl) (rep, ). (Entered: 05/24/2001)

REPLY LETTER: dated 6/6/01 by John D. Giansello, Esq., on behalf of Carrols Corporation to response to and in further support of [29-1] motion to Compel the plaintiff to respond further to discovery requests (Leave to file granted by chambers, GLS) (jmb) (rep, ). (Entered: 06/12/2001)

REPLY LETTER: dated 6/20/01 by Michelle A. Caiola, Esq., on behalf of Equal Employment to response to and in further support of [31-2] Cross Motion to Compel outstanding discovery; w/attached exhibits 6, 7, and 8. (Leave to file granted by Chambers, GLS) (jmb) (mc, ). (Entered: 06/26/2001)

LETTER REQUEST & ORDER: dated 5/14/02 by John D. Giansello, Esq., on behalf of defendant Carrols Corporation, requesting leave to file a memorandum of law of 40 pages in length due to the complex legal issues, request is modified by the Court and granted, the deft. may file a 30 page memorandum of law. (Signed by Chief Judge F. J. Scullin Jr.) (jmb) (Entered: 05/20/2002)

MOTION by John D. Giansello, Esq., on behalf of Carrols Corporation for Summary Judgment dismissing the Complaint, w/attached material facts statement, supporting declarations, and exhibits A through V, Hearing set for 10/11/02 at 10:00 AM, Motion returnable before Chief Judge: Scullin {This motion was received on 9/5/02, however is considered filed as of 6/18/02, the original date of service, pursuant to the CJRA reporting requirements instituted on 3/1/00} (jmb) Modified on 09/05/2002 (jmb, ). (Entered: 09/05/2002)

LETTER by John D. Giansello, Esq., on behalf of Carrols Corporation pursuant to Local Rule 7.1(b) regarding service of Motion: for Summary Judgment, Date Served upon counsel: 6/18/02 (jmb) (mc, ). (Entered: 06/25/2002)

LETTER by Adela Santos, Esq., on behalf of Equal Employment pursuant to Local Rule 7.1(b) regarding response to deft's Motion for Summary Judgment and EEOC's Motion for Summary Judgment pursuant to Rule 56(f) granting a Continuance; Date Served upon counsel: 7/23/02 (jmb) (mc, ). (Entered: 08/05/2002)

MOTION by Equal Employment for a Continuance pursuant to Rule 56(f) of the FRCvP, Hearing set for 10/11/02 at 10:00 AM, w/attached memorandum of law and declaration, and exhibits A through D, Motion returnable before Chief Judge Scullin {This motion was received on 9/5/02, however is considered filed as of 7/24/02, the original date of service, pursuant to the CJRA reporting requirements instituted on 3/1/00} (jmb) (jmb, ). (Entered: 09/05/2002)

LETTER by John D. Giansello, Esq., on behalf of Carrols Corporation pursuant to Local Rule 7.1(b) regarding service its' reply papers to Carrols Corp's Motion for Summary Judgment and opposition to EEOC's Cross Motion, Served upon counsel: 8/20/02 (jmb) (mc, ). (Entered: 08/27/2002)

DECLARATION: by Gerald DiGenova, Vice President of Carrols Corporation in support of [38-1] Motion for Summary Judgment dismissing the Complaint, w/attached exhibits A through Z and AA through OO. (jmb) (jmb, ) (Entered: 09/05/2002)

DECLARATION: by Andrew Baron Esq., on behalf of Carrols Corporation in support of [38-1] Motion for Summary Judgment dismissing the Complaint, w/attached exhibits A through J. (jmb) (jmb, ). (Entered: 09/05/2002)

EXHIBIT K (PART 1): by Carrols Corporation, in further support of Andrew Baron's Declaration. (jmb) (Additional attachment(s) added on 8/2/2017: # 1 Part 2 of 2) (jmb, ). (Entered: 09/05/2002)

EXHIBIT K (PART 2): by Carrols Corporation, in further support of Andrew Baron's Declaration. (jmb) (Attachments added on 8/4/2017: # 1 Exhibit 143 (continued - Part 2) through Exhibit 161) (jmb, ) (Entered: 09/05/2002)

MEMORANDUM OF LAW: by John D. Giansello, Esq., on behalf of Carrols Corporation in support of [38-1] Motion for Summary Judgment dismissing the Complaint (30 pages, Approved) (jmb) (mc, ). (Entered: 09/05/2002)

RESPONSE & REPLY MEMORANDUM: by John D. Giansello, Esq., on behalf of Carrols Corporation in opposition to [44-1] Motion for a Continuance pursuant to Rule 56(f) of the FRCvP and reply to response to and in further support of [38-1] Motion for Summary Judgment dismissing the Complaint, w/attached Reply Declaration. (jmb) (jmb, ). (Entered: 09/05/2002)

MOTION/REQUEST & ORDER: plaintiff's move for leave of the Court to reply to the defts' reply, request granted the plaintiff is granted leave to sur-reply. (Signed by Chief Judge Frederick J. Scullin Jr.) (jmb) Modified on 09/20/2002 (Entered: 09/20/2002)

LETTER REQUEST & ORDER: dated 9/27/02 by Adela P. Santos, Esq., on behalf of the plaintiff, requesting an adjournment of the motion hearing, Motion Hearing set for 10/16/02 at 2:00 PM, Re: [38-1] Motion for Summary Judgment dismissing the Complaint and [44-1] Motion for a Continuance pursuant to Rule 56(f) of the FRCvP (Signed by Chief Judge Frederick J. Scullin Jr.) (jmb) (Entered: 10/07/2002)

Scheduling Notice: Motion Hearing reset for 11/13/02 at 4:00 PM, Re: [38-1] Motion for Summary Judgment dismissing the Complaint, and [44-1] Motion for a Continuance pursuant to Rule 56(f) of the FRCvP (Sent by Courtroom Clerk: Barbara J. Woodford) (jmb) (mc, ). (Entered: 10/17/2002)

Minute entry: Motion Argument held. Claims: Title VII sex-based job discrimination, retaliation and hostile work environment. Discovery Motion to continue discovery is argued. Pltf requests discovery be reopened for depositions of parties listed in their moving papers to determine a pattern and practice by the deft. Deft objects and cites case law to support argument. Court advises that Pltf must show evidence of intentional discrimination in order for the Court to allow further discovery to establish a pattern and practice by Deft re: handling sex-based Job discrimination claims. Pltf has not responded to Defts motion for Summary Judgment due to motion pending for further discovery. Pltf believes more discovery is necessary before they are able to respond to this motion. [44-1] motion for a Continuance pursuant to Rule 56(f) of the FRCvP Reserved, [38-1] motion for Summary Judgment dismissing the Complaint Reserved. APP: Adela Santos, Esq. for Pltf; John Giansello III, Esq.; Michael Delikat, Esq.; Joseph Zuckman, Esq. and Jeff Mayer, Esq. for Deft.; Court Reporter/ECRO: Jodi Hibbard; LC: AAD (bjw) (Entered: 11/14/2002)

ORDER: denying [38-1] defendant's Motion for Summary Judgment dismissing the Complaint, and denying plaintiff's [44-1] Motion for a Continuance pursuant to Rule 56(f) of the FRCvP, as moot, further ordered that this case is recommitted to the Magistrate Judge with instructions to set new discovery deadlines and to allow additional limited discovery on the issue of whether defendant engaged in a pattern or practice of intentional discrimination, the parties are directed to initiate contact with the Magistrate Judge within 10 days of this order, finally the parties are shall renew or file dispositive motions within 60 days of the close of discovery. (Signed by Chief Judge Frederick J. Scullin Jr.) (jmb) (Entered: 11/21/2002)

Docket Annotation

Atty's contacted court pursuant to Judge Scullin's order to schedule a conference. Court will send out notice for a telephone conference on 12/3/02 at 10:00 (jlm)

Minute entry of Telephone Conference before Mag/Judge Sharpe: the parties discuss outstanding summaries and questionnaires, Judge directs the EEOC to supply the summaries to the defts, pltf requests to take additional depositions, deft. opposes the request, Judge will issue an order within 2 weeks, if a further conference needs to be scheduled the Court will notice the parties; App: Asuna Chaney, Esq., Adela Santos, Esq., John Giansello, Esq., Joseph Zurkman, Esq., Court Clerk: Judy L. Baugh; Tape #183 (jmb) (Entered: 12/13/2002)

TRANSCRIPT OF MOTION ARGUMENT: filed for the date of November 13, 2002 before Chief Judge Scullin. (Court Reporter: Jodi L. Hibbard) (jmb) (mc, ). (Entered: 12/13/2002)

NOTICE/LETTER BRIEF: dated 12/13/02 by John D. Giansello, Esq., on behalf of Carrols Corporation, advising the Court that he has received the Court Transcript of the 11/13/02 Motion Hearing and attaches it for the Court's reference, and he gives a summary of his client's position on the outstanding discovery issues. (jmb) (mc, ). (Entered: 12/30/2002)

LETTER RESPONSE by Adela P. Santon, Esq for Equal Employment in response the the [53-1] Letter (jlm) (jmb, ). (Entered: 01/22/2003)

DECISION & ORDER: granting in part, denying in part deft's [29-1] Motion to Compel pltf to respond further to discovery requests, and granting in part, denying in part pltf's [31-2] Motion to Compel, deadline for compliance with production as stated in this Order is 4/14/03 and various disclosure and deposition shall be concluded by 5/14/03, the parties shall consult and confer and thereafter notify the Court in writing by 3/14/03 concerning any other outstanding case management or non-dispositive issues and a proposed dispositive motion filing deadline. (Signed by Magistrate Judge Gary L. Sharpe) (jmb) (Entered: 02/18/2003)

LETTER/NOTICE dated 3/13/03; Letter addressed to Mj Sharpe from Judy Keenan, Esq. for pltf. Equal Employment; Letter is in compliance with teh Court's 2/18/03 Order, directing parties to file letters re: outstanding matters; Attached Exhibit A (kcl) (mc, ). (Entered: 03/17/2003)

Received call from defts' atty John Giansello for a request to file the status letter due 3/14/03 on 3/18/03. Letter will be Fed Ex to be received in Syracuse no later than 3/18/03. (jlm)

Docket Annotation

LETTER/NOTICE dated 3/17/03; Letter addressed to MJ Sharpe from John Giansello, Esq. for deft. Carrols Corporation; Counsel complies with the Court's 2/18/03 order, advising the Court of unresloved issues (kcl) (mc, ). (Entered: 03/18/2003)

Letter application received from Judy Keenean, Esq. for pltf. Equal Employment requesting: that a conference be held to Resolve Discovery Disputes; Attached Exhibits A-G (kcl) (jmb, ). (Entered: 07/14/2003)

LETTER/RESPONSE dated 7/14/03; Letter addressed to Judge Sharpe from John Giansello, Esq., counsel for deft. Carrols Corporation in opposition to pltfs. [58-1] Letter application (kcl) Modified on 07/15/2003 (mc, ). (Entered: 07/15/2003)

LETTER/NOTICE dated 7/16/03; Letter addressed to MJ Sharpe from Judy Keenan, Esq., counsel for pltf. Equal Employment; counsel responds to defts. letter dated 7/14/03; EEOC reaffirms their request for an opportunity to discuss the Discovery matters in a conference with the Court; Attached Exhibit H (kcl) (jmb, ). (Entered: 07/17/2003)

LETTER by John Giansello, Esq. for deft. Carrols Corporation pursuant to Local Rule 7.1(b) regarding Renewed Motion for Summary Judgment; Date Served upon counsel: 7/18/03 (kcl) (mc, ). (Entered: 07/21/2003)

LETTER/NOTICE dated 7/22/03; Letter addressed to MJ Sharpe from John Giansello, Esq. for Carrols Corporation; Letter responding to the 3rd letter of the EEOC regarding their Discovery requests (kcl) (mc, ). (Entered: 07/24/2003)

LETTER titled "EEOC's Request for Expedited Ruling on Outstanding Discovery Matters and Dispositive Motion Briefing Schedule Due to the Service of Deft's Renewed SJ Motion" dd 7/21/03 by Judy Keenan, Esq for Equal Employment with a Proposed Order attached. (jlm) (mc, ). (Entered: 08/01/2003)

LETTER/NOTICE dated 7/30/03; Letter addressed to MJ Sharpe from Lisa Sirkin, Esq., counsel for Equal Employment; Counsel requests that the Court allow an extension for pltfs. to respond to the defts. motion for Summary Judgment (kcl) (mc, ). (Entered: 07/31/2003)

Scheduling Notice: Letter advising counsel for parties that the Court has set a Telephone Conference for 10:00 8/7/03 with MJ Sharpe; Pltfs atty. is to initiate the call; Notice sent by JLM (kcl) (mc, ). (Entered: 08/04/2003)

LETTER/NOTICE dated 7/31/03; Letter addressed to MJ Sharpe from John Giansello, Esq. for deft. Carrols Corporation; Counsel confirms receipt of the EEOC's latest submission to the court and further opposes the extension of time requested by the EEOC (kcl) (mc, ). (Entered: 08/05/2003)

Minute entry of telephone conference with Mag. Judge Sharpe; APPR: Judy Kenna, Esq, Lisa Serkin, Esq and Asuna Chaney, Esq all for pltf; John Giansello, Esq for deft Carrol's; Joseph Zurkman, Esq for deft; Mike Delikat, Esq for deft; Judge Sharpe holds a telephone conference on the recent correspondence received by the parties; EEOC wants to take 14 more depositions; Judge Sharpe will not allow any more extensions to do depositions; Judge Sharpe makes his ruling and orders the following: 75 days from today EEOC is to identify their experts; Depositions to be completed by 10/7/03; Pltf's to identify their experts on or before 10/22/03; Carrol's to Disclose rebuttal experts, if any, on or before 11/21/03; Depositions of experts to be completed no later than 12/22/03; Carrol's to file their summary judgment on or before 1/22/04 with responses to be filed in accordance with new rules; Judge Sharpe explains to the parties, any extensions regarding the summary judgment motion shall be directed to the District Judge. Court Reporter: Kristine Sellin; Court Clerk: Judi McNicholas. (jlm) (mc, ). (Entered: 08/26/2003)

Tele-conference held with Mag. Judge Sharpe. (jlm)

Deadline updated; SJ Motion Filing deadline to 1/22/04 as Ordered by Judge Sharpe on 8/7/03 (jlm)

Telephone Conference

Set Deadlines/Hearings

TRANSCRIPT filed for dates of 8/7/03 for Tel. Conf. w/MJ Sharpe. (lmp) (mc, ). (Entered: 08/25/2003)

LETTER/NOTICE dated 9/30/03; Letter addressed to MJ Sharpe from John Giansello, Esq., counsel for Carrols Corporation; lEtter seeks the Court's clarification of certain points in the discovery and scheduling order issued by the court on 8/7/03; Attachments (kcl) (jmb, ). (Entered: 10/02/2003)

LETTER/NOTICE dated 10/10/03; Letter addressed to MJ Sharpe from Sunu Chandy, Esq. in opposition to defts. letter dated 9/30/03 wherein they seek Clarification of certain points in the discovery and scheduling order issued by the Court (kcl) (mc, ). (Entered: 10/14/2003)

LETTER/NOTICE dated 10/14/03; Letter addressed to MJ Sharpe from John Giansello, Esq., counsel for Carrols Corporation; Counsel replies to EECO's response to pltfs. 9/30/03 request for clarification (kcl) (mc, ). (Entered: 10/15/2003)

Amended MOTION for Summary Judgment /Amended Notice Of Renewed Motion For Summary Judgment by Carrols Corporation. (Attachments: # 1 Defendant's Amended Revised And Augmented Local Rule 7.1(a)(3) Statement In Support Of Renewed Motion For Summary Judgment (Part I)# 2 Defendant's Amended Revised And Augmented Local Rule 7.1(a)(3) Statement In Support Of Renewed Motion For Summary Judgment (Part II)# 3 Amended Supplemental Declaration Of John D. Giansello In Support Of Defendant's Renewed Motion For Summary Judgment ( Exhibits filed conventionally )# 4 Declaration Of Allison R. Fried In Support Of Defendant's Renewed Motion For Summary Judgment ( Exhibits filed conventionally )# 5 Amended Declaration Of Michael J. Peters In Support Of Defendant's Renewed Motion For Summary Judgment ( Exhibits filed conventionally )# 6 Declaration Of Jesica Golden In Support Of Defendant's Renewed Motion For Summary Judgment ( Exhibit filed conventionally )# 7 Defendant's Revised Memorandum In Support Of Its Renewed Motion For Summary Judgment ( Appendices filed conventionally )# 8 Certificate Of Service)(Giansello, John) (Entered: 01/16/2004)

2 Defendant's Amended Revised And Augmented Local Rule 7.1(a)(3) Statement I

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3 Defendant's Amended Revised And Augmented Local Rule 7.1(a)(3) Statement I

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4 Amended Supplemental Declaration Of John D. Giansello In Support Of Defendant&#

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5 Declaration Of Allison R. Fried In Support Of Defendant's Renewed Motion F

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6 Amended Declaration Of Michael J. Peters In Support Of Defendant's Renewed

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7 Declaration Of Jesica Golden In Support Of Defendant's Renewed Motion For

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8 Defendant's Revised Memorandum In Support Of Its Renewed Motion For Summar

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9 Revised Memorandum with Appendix A through H

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10 Supporting Exhibits to Amened Declaration of John D. Giansello - Exhibits A - Z

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Set Motion and R&R Deadlines/Hearings

Set Deadlines as to 72 Amended/Renewed MOTION for Summary Judgment. Motion Hearing set for 3/12/2004 at 10:00 AM in Syracuse before Chief Judge Frederick J. Scullin Jr. Response to Motion due by 2/25/2004. Reply to Response to Motion due by 3/1/2004. (Deadlines were inadvertently not added to motion entry) (jmb)

ORDER REASSIGNING CASE. Case reassigned to Magistrate Judge George H. Lowe. Judge Gary Sharpe no longer assigned to case. Signed by Judge Frederick J. Scullin Jr. on 2/11/04. (kcl, ) (Entered: 02/11/2004)

Confirmation of Deadlines as to 72 Amended/Renewed MOTION for Summary Judgment, due to an clerical error the deadlines related to this motion were set in ECF incorrectly, Debbie Moore of Judge Scullin's chambers has authorized the deadlines to remain as set allowing the parties one additional day to submit the response and reply papers herein, this confirms that the deadlines are: Response to Motion deadline is 2/25/2004 and Reply to Response to Motion deadline is 3/1/2004. The Motion Hearing remains set for 3/12/2004 at 10:00 AM in Syracuse before Chief Judge Frederick J. Scullin Jr. (jmb)

Set Motion and R&R Deadlines/Hearings

Reset Reply to Response to Motion Deadline as to 72 Amended/Renewed MOTION for Summary Judgment, upon authorization of Debbie Moore of Judge Scullin's chambers, the Clerk is directed to update the Reply to Response to Motion deadline to 3/2/2004 to allow the reply to be due 6 days after the filing of the response per the local rules. (jmb)

Set Motion and R&R Deadlines/Hearings

Set/Reset Deadlines as to 72 Amended MOTION for Summary Judgment /Amended Notice Of Renewed Motion For Summary Judgment. Motion Hearing set for 3/12/2004 10:00 AM in Syracuse before Chief Judge Frederick J. Scullin Jr.. (kcl, )

MOTION to Seal Document/motion by Sunu Chandy, Esq. for Equal Employment Opportunity Commission.(kcl, ) (Entered: 02/26/2004)

NOTICE by Sunu Chandy, Esq., counsel for Equal Employment Opportunity Commission; counsel requests that the Court grant permission to file a motion to exclude (kcl, ) (Entered: 02/26/2004)