Case: EEOC v. Unified Investigations and Sciences, Inc.

EEOC v. Unified Invest & Sci

Equal Employment Opportunity Commission and Leslie O'Toole v. Unified Investigations & Sciences, Inc.

EEOC v. Unified Investigations & Sciences, Inc.

No Court

Carly Knight, Frank Dobbin, Alexandra Kalev

COMPLAINT FOR INJUNCTION AND DAMAGES FOR SEX DISCRIMINATION, RETALIATION, VIOLATION OF THE WASHINGTON EQUAL PAY STATUE, and BREACH OF CONTRACT JURY DEMAND (Summons(es) issued) Receipt # 262717 (PM) (Entered: 10/27/1999)

NOTICE OF ATTORNEY APPEARANCE for plaintiff by Jesse Wing (PM) (Entered: 10/27/1999)

ATTORNEY APPEARANCE for defendant Unified Invest & Sci by atty Richard H Guelich IV (CL) (Entered: 11/02/1999)

ORDER/NOTICE OF JOINT STATUS REPORT Joint Status Report due 1/27/99 (cc: counsel) (CL) (Entered: 11/05/1999)

ORDER re: DISCOVERY and DEPOSITIONS by Judge Thomas S. Zilly (cc: counsel) (CL) (Entered: 11/05/1999)

ANSWER to complaint [1-1] by defendant (KERR) (Entered: 11/30/1999)

JOINT STATUS REPORT filed by all parties. Est. Trial Days: 4-5 Attornies: Richard H Guelich IV for defendant Unified Invest & Sci, Jesse Andrew Wing for plaintiff Leslie O'Toole(LW) Modified on 12/28/1999 (Entered: 12/28/1999)

ORDER REGARDING SCHEDULING AND OTHER PRETRIAL MATTERS by Judge Thomas S. Zilly ; jury trial 2/5/01 Deadline to Join Additional Parties is 4/28/00 ; ; discovery ddl 11/7/00 Disclose Expert Witnesses by 9/8/00 ; Disclose Rebuttal Expert Witnesses by 11/20/00 ; mtn filing ddl 11/9/00 Motions in Limine deadline <date not set> ; ; pretrial order ddl 1/16/01 ; trial brief ddl 1/31/01 ; Voir dire/jy inst 1/31/01 ; pretrial conf 3:00 1/19/01 (cc: counsel, Judge) (RS) (Entered: 01/19/2000)

ORDER DESIGNATING CASE FOR MEDIATION by Judge Thomas S. Zilly ; Mediation shall be completed within 60 days after completion of discovery. (cc: counsel, Judge) (RS) (Entered: 01/19/2000)

STIPULATION to amend complaint (CL) (Entered: 02/06/2000)

AFFIDAVIT OF SERVICE by plaintiff Leslie O'Toole of stipulation [10-1], etc. (CL) (Entered: 02/06/2000)

FIRST AMENDED COMPLAINT FOR INJUNCTION AND DAMAGES (ORIGINAL COPY) re: stipulation [10-1] (CL) Modified on 02/10/2000 (Entered: 02/06/2000)

MINUTE ORDER is made by direction of the Court, the Honorable Thomas S. Zilly, US District Judge. The Court grants the stipulated motion to amend complaint/docket #10. (cc: counsel, Judge) (CL) (Entered: 02/10/2000)

MOTION by plaintiff to consolidate cases w/C00-69 NOTED FOR 2/25/00 (MD) (Entered: 02/14/2000)

LODGED ORDER: re: motion to consolidate cases w/C00-69 [14-1] (MD) (Entered: 02/14/2000)

ORDER CONSOLIDATING ACTIONS by Judge Thomas S. Zilly. GRANTING pltfs' motion to consolidate cases w/C00-69 [14-1]. Consolidating case CV00-69P into CV99-1676Z. All pleadings and other papers filed in CV00-69 shall be filed under CV99-1676Z, and both cases shall be heard before Honorable Thomas S. Zilly. (cc: counsel, Judge) (CL) Modified on 03/10/2000 (Entered: 03/10/2000)

ANSWER to complaint [1-1] by defendant (VK) (Entered: 06/05/2000)

MINUTES of telephone conference: TSZ; Dep Clerk: CC; Counsel J. Wing, L. Guarnero, R. Guelich; parties directed to agree on depo dates for Mr. Roberts and Ms. O'Toole; Court allows the videotaping of Ms. O'Toole's dep (dktclk) (Entered: 09/29/2000)

MOTION by plaintiffs for protective order NOTED FOR 11/3/00 (CL) (Entered: 10/19/2000)

MEMORANDUM by plaintiffs` in support of motion for protective order [18-1] (CL) (Entered: 10/19/2000)

DECLARATION of Jesse Wing by plaintiffs in support of motion for protective order [18-1] (CL) (Entered: 10/19/2000)

MOTION by plaintiffs to shorten time on motion for protective order [18-1] NOTED FOR 10/23/00 (CL) (Entered: 10/19/2000)

AFFIDAVIT of Jesse Wing in support of motion to shorten time on motion for protective order [18-1] [21-1] (CL) (Entered: 10/19/2000)

AFFIDAVIT OF SERVICE by plaintiffs of motion for protective order [18-1], etc. (CL) (Entered: 10/19/2000)

LODGED ORDER: re: motion for protective order [18-1] (CL) (Entered: 10/19/2000)

LODGED ORDER: re: motion to shorten time on motion for protective order [18-1] [21-1] (CL) (Entered: 10/19/2000)

ORDER by Judge Thomas S. Zilly GRANTING motion to shorten time on motion for protective order [18-1] [21-1], RENOTED FOR 10/24/00 motion for protective order [18-1] (cc: counsel, Judge) (CL) (Entered: 10/20/2000)

RESPONSE by defendant in 2:99-cv-01676 to motion for protective order [18-1] (KERR) (Entered: 10/28/2000)

RESPONSE by defendant in 2:99-cv-01676 re: messenger slip reflecting receipt re: motion response [25-1] (MD) (Entered: 10/30/2000)

DECLARATION of Jesse Wing by plaintiff re: motion reply [27-1] (VK) (Entered: 10/31/2000)

AFFIDAVIT OF SERVICE by plaintiff of motion reply [27-1] etc. (VK) (Entered: 10/31/2000)

MINUTE ORDER is made by direction of the Court, the Honorable Thomas S. Zilly, US District Judge. The Court GRANTS pltf's motion for protective order [18-1] as to pltf's sexual or romantic history. DENIES mtn for protective order (18-1) as to the pltf's medical history. (cc: counsel, Judge) (CL) (Entered: 11/02/2000)

MOTION by plaintiff in 2:99-cv-01676 to exclude deft's expert witness Dr. Shirley Feldman-Summers NOTED FOR 11/17/00 (MD) (Entered: 11/06/2000)

MEMORANDUM by plaintiff Leslie O'Toole in 2:99-cv-01676 in support of motion to exclude deft's expert witness Dr. Shirley Feldman-Summers [31-1] (MD) (Entered: 11/06/2000)

DECLARATION of Jesse Wing re motion to exclude deft's expert witness Dr. Shirley Feldman-Summers [31-1] (MD) (Entered: 11/06/2000)

AFFIDAVIT OF SERVICE by plaintiff in 2:99-cv-01676 of motion to exclude deft's expert witness Dr. Shirley Feldman-Summers [31-1] (MD) (Entered: 11/06/2000)

LODGED ORDER: re: motion to exclude deft's expert witness Dr. Shirley Feldman-Summers [31-1] (MD) (Entered: 11/06/2000)

AFFIDAVIT OF SERVICE OF DEPOSITION SUBPOENA of Kathy Forgey on 10/28/00 (RS) (Entered: 11/08/2000)

AFFIDAVIT OF SERVICE OF DEPOSITION SUBPOENA of Teresa Norman on 10/28/00 (RS) (Entered: 11/08/2000)

MOTION by plaintiff Leslie O'Toole and plaintiff EEOC to extend ddl for disclosing rebuttal expert witnesses NOTED FOR 11/24/00 (VK) (Entered: 11/09/2000)

DECLARATION of Jesse Wing by plaintiff in 2:99-cv-01676 re motion to extend ddl for disclosing rebuttal expert witnesses [37-1] (VK) (Entered: 11/09/2000)

AFFIDAVIT OF SERVICE by plaintiff in 2:99-cv-01676 of motion to extend ddl for disclosing rebuttal expert witnesses [37-1] etc. (VK) (Entered: 11/09/2000)

LODGED ORDER: re: granting pltfs' motion to extend ddl for disclosing rebuttal expert witnesses [37-1] (VK) (Entered: 11/09/2000)

WITHDRAWAL by plaintiff in 2:99-cv-01676 of motion to exclude deft's expert witness Dr. Shirley Feldman-Summers [31-1] (KERR) (Entered: 11/20/2000)

RESPONSE by defendant Unified Invest & Sci in 2:99-cv-01676 to pltfs' motion to extend ddl for disclosing rebuttal expert witnesses [37-1] (MD) (Entered: 11/22/2000)

EXPERT REBUTTAL WITNESS DISCLOSED by defendant (RS) (Entered: 11/24/2000)

WITHDRAWAL by plaintiff in 2:99-cv-01676 of motion to extend ddl for disclosing rebuttal expert witnesses [37-1] (MD) (Entered: 11/27/2000)

MINUTE ORDER: by Judge Thomas S. Zilly STRIKING as moot pltf's motion to extend ddl for disclosing rebuttal expert witnesses [37-1] (cc: counsel, Judge) (KERR) (Entered: 12/01/2000)

MOTION by plaintiff Leslie O'Toole, plaintiff EEOC in 2:99-cv-01676 for leave to take additional limited discovery regarding dft's recent filing of criminal charges against pltf O'Toole NOTED FOR 1/19/01 (CL) Modified on 01/02/2001 (Entered: 01/02/2001)

DECLARATION of Lisa M. Guarnero by plaintiff Leslie O'Toole in 2:99-cv-01676, plaintiff EEOC in 2:99-cv-01676 re motion for leave to [46-1] (CL) (Entered: 01/02/2001)

MOTION by plaintiff Leslie O'Toole in 2:99-cv-01676, plaintiff EEOC in 2:99-cv-01676 to shorten time on motion for leave to [46-1] NOTED FOR 1/3/01 (CL) (Entered: 01/02/2001)

AFFIDAVIT of Lisa Guarnero in support of motion to shorten time on motion for leave to [46-1] [49-1] (CL) (Entered: 01/02/2001)

AFFIDAVIT OF SERVICE by plaintiff Leslie O'Toole in 2:99-cv-01676, plaintiff EEOC in 2:99-cv-01676 of motion for leave to [46-1], etc. (CL) (Entered: 01/02/2001)

LODGED ORDER: re: motion to shorten time on motion for leave to [46-1] [49-1] (CL) (Entered: 01/02/2001)

MEMORANDUM by plaintiffs Leslie O'Toole in 2:99-cv-01676, plaintiff EEOC in 2:99-cv-01676 in support of motion for leave to [46-1] (CL) (Entered: 01/02/2001)

LODGED ORDER: re: motion for leave to take additional limited discovery regarding dft's recent filing of criminal charges against pltf O'Toole [46-1] (CL) (Entered: 01/02/2001)

RESPONSE by defendant to motion to shorten time on motion for leave to [46-1] [49-1] (RS) (Entered: 01/09/2001)

MINUTE ORDER: by Judge Thomas S. Zilly GRANTING pltf's motion to shorten time on motion for leave to take additional ltd disc [46-1] [49-1], GRANTING pltf's motion for leave to take additional limited discovery regarding dft's recent filing of criminal charges against pltf O'Toole [46-1]. The depositions shall be completed by 1/31/01 (cc: counsel, Judge) (KERR) (Entered: 01/10/2001)

LODGED PRE-TRIAL ORDER submitted by all parties (RS) (Entered: 01/19/2001)

MINUTES OF PRETRIAL CONF: TSZ; Dep Clerk: C Condon; cnsl present; parties advise mediation has failed; Motions in Limine deadline 1/23/01 ; ct to sign pretrial order (RS) (Entered: 01/22/2001)

AFFIDAVIT OF SERVICE OF DEPOSITION SUBPOENA of Susan Quant on 1/17/01 (RS) (Entered: 01/24/2001)

MOTION by plaintiff in limine to exclude evidence of pltf O'Toole's history of prior substance abuse NOTED FOR 2/5/01 (RS) (Entered: 01/24/2001)

MOTION by plaintiff in limine to limit the number of medical experts the dft can call to testify NOTED FOR 2/5/01 (RS) (Entered: 01/24/2001)

MOTION by plaintiff in limine to strike new affirmative defense of fraud/misrepresentation and admission of evidence NOTED FOR 2/5/01 (RS) (Entered: 01/24/2001)

MOTION by plaintiff in limine to exclude evidence of pltf O'Toole's 1991 lawsuit NOTED FOR 2/5/01 (RS) (Entered: 01/24/2001)

MOTION by plaintiff in limine to bar evidence of salaries of employees, etc NOTED FOR 2/5/01 (RS) (Entered: 01/24/2001)

MOTION by plaintiff in limine to exclude uncertified and very imcomplete depo trans from pltf, etc NOTED FOR 2/5/01 (RS) (Entered: 01/24/2001)

AFFIDAVIT OF SERVICE by plaintiff in 2:99-cv-01676 of motion in limine to exclude evidence of pltf O'Toole's history of prior substance abuse [56-1] etc (RS) (Entered: 01/24/2001)

MOTION by plaintiff EEOC in limine to exclude use of pltf O'Toole's prior employ. record NOTED FOR 2/5/01 (RS) (Entered: 01/24/2001)

MOTION by plaintiff EEOC in limine to introduce depo transcripts of Eddie Smith and Jerry James at trial NOTED FOR 2/5/01 (RS) (Entered: 01/24/2001)

MOTION by plaintiff EEOC in limine to exclude lay witness opinion testimony re general employment of females... NOTED FOR 2/5/01 (RS) (Entered: 01/24/2001)

MOTION by plaintiff EEOC to strike EEOC investigator Paul Washington from dft's witness list NOTED FOR 2/5/01 (RS) (Entered: 01/24/2001)

DECLARATION of Lisa Guarnero by plaintiff EEOC re motion to strike EEOC investigator Paul Washington from dft's witness list [66-1] (RS) (Entered: 01/24/2001)

MOTION by defendant in limine to preclude witnesses NOTED FOR 2/5/01 (RS) (Entered: 01/26/2001)

MEMORANDUM by defendant in 2:99-cv-01676 in support of motion in limine to preclude witnesses [69-1] (RS) (Entered: 01/26/2001)

LODGED ORDER: re: motion in limine to preclude witnesses [69-1] (RS) (Entered: 01/26/2001)

LODGED ORDER: re: motion in limine to exclude evidence of pltf O'Toole's history of prior substance abuse [56-1] etc (RS) (Entered: 01/24/2001)

REPORT regarding failure of mediation that occured on 1/8/01; request for settlement judge (RS) (Entered: 01/26/2001)

AFFIDAVIT OF SERVICE OF DEPOSITION SUBPOENA of Susan Quant on 1/22/01 (RS) (Entered: 01/26/2001)

RESPONSE by plaintiff to dft's motion in limine to exclude rebuttal witness treating Dr Feldman (RS) (Entered: 01/30/2001)

DECLARATION of Jesse Wing by plaintiff in 2:99-cv-01676 re: motion response [73-1] (RS) (Entered: 01/30/2001)

AFFIDAVIT OF SERVICE by plaintiff in 2:99-cv-01676 motion response [73-1] etc (RS) (Entered: 01/30/2001)

RESPONSE by plaintiff EEOC to dft's motion to exclude class members from testifying at trial and opposition to dft's motion to dismiss (RS) (Entered: 01/30/2001)

MOTION by defendant Unified Invest & Sci in limine (CL) (Entered: 01/30/2001)

LODGED ORDER: denying dft's motions in limine to exclude Dr Feldman (RS) (Entered: 01/30/2001)

LODGED ORDER: re: motion in limine [77-1] (CL) (Entered: 01/30/2001)

ENT- A settlement conference has been scheduled before Judge Sweigert for Thursday, Feb. 1 at 1 pm. Cnsl. advise by telephone. (EM) (Entered: 01/30/2001)

JURY INSTRUCTIONS by plaintiff Leslie O'Toole plaintiff EEOC (RS) (Entered: 02/01/2001)

VOIR DIRE submitted by plaintiff Leslie O'Toole and plaintiff EEOC (RS) (Entered: 02/01/2001)

Proposed Jury Verdict Form by plaintiff Leslie O'Toole and plaintiff EEOC (RS) (Entered: 02/01/2001)

AFFIDAVIT OF SERVICE by plaintiffs re verdict form [81-1] etc (RS) (Entered: 02/01/2001)

TRIAL BRIEF submitted by plaintiff in 2:99-cv-01676 (RS) (Entered: 02/02/2001)

TRIAL BRIEF submitted by defendant Unified Invest & Sci in 2:99-cv-01676, (MD) (Entered: 02/05/2001)

MINUTE ORDER is made by direction of the Court, the Honorable Thomas S. Zilly, US District Judge, GRANTING pltf's motion in limine to strike new affirmative defense of fraud/misrepresentation and admission of evidence [58-1] DENYING pltf's motion in limine to exclude evidence of pltf O'Toole's history of prior substance abuse [56-1] GRANTING pltf's motion in limine to limit the number of medical experts the dft can call to testify [57-1] GRANTING pltf's motion in limine exclude evidence of pltf O'Toole's 1991 lawsuit [59-1] GRANTING AND DENYING pltf's motion in limine to bar evidence of salaries of employees, etc [60-1] GRANTING pltf's motion in limine to exclude uncertified and very imcomplete depo trans from pltf, etc [61-1] DENYING pltf's motion in limine to exclude use of pltf O'Toole's prior employ. record [63-1] GRANTING pltf's motion in limine to introduce depo transcripts of Eddie Smith and Jerry James at trial [64-1] DENYING motion to strike EEOC investigator Paul Washington from dft's witness list [66-1] EEOC's mtn to exclude lay witnesses opinion testimony, docket #65 is DEFERRED until trial, defense mtn to preclude witnesses, docket #69 is DEFERRED until trial(cc: counsel, Judge) (CL) (Entered: 02/01/2001)

TRIAL BRIEF submitted by plaintiffs (RS) (Entered: 02/01/2001)

MINUTE ORDER: by Judge Thomas S. Zilly DENYING dft's motion in limine to preclude witnesses [69-1] (cc: counsel, Judge) (RS) (Entered: 02/02/2001)

LODGED ORDER: consent decree (RS) (Entered: 02/21/2001)

MINUTE ORDER: by Judge Thomas S. Zilly directing pltf O'Toole and dft to reimburse court for jury costs in amount of $1,754.47. Pltfs and dft to pay $584.82 each within 30 days (cc: counsel, Judge, fin'l, jury) (RS) (Entered: 02/23/2001)

CONSENT DECREE by Judge Thomas S. Zilly (cc: counsel, Judge, Jgm. Book) Entered on: 3/15/01 (RS) (Entered: 03/15/2001)

ORDER OF DISMISSAL by Judge Thomas S. Zilly : Counsel having notified the Court of settlement of this case, and it appearing that no issue remains for the Court's determination, IT IS ORDERED that this action and all claims asserted herein are DISMISSED with prejudice and without costs to any party. In the event that settlement is not perfected, any party may move to reopen the case within 60 days of the date of this order (cc: counsel, Judge) (RS) (Entered: 03/15/2001)