Case: EEOC v. Convergys Customer Management Group, Inc.

EEOC v. Convergys Customer

U.S. Court of Appeals for the Eighth Circuit

Carly Knight, Frank Dobbin, Alexandra Kalev

COMPLAINT against defendant Convergys Customer Management Group, Inc. Waivers issued 1, Consents issued 2, Disclosure of Corporate Interest issued to deft, Jury Demand,, filed by Equal Employment Opportunity Commission. (Attachments: # 1 Civil Cover Sheet # 2 Original Filing Form)(SAJ, ) (Entered: 07/08/2004)

ENTRY of Appearance by Laura M. Jordan Defendant Convergys Customer Management Group, Inc.. (Jordan, Laura) (Entered: 07/16/2004)

CJRA ORDER (jgw). Judge Terry I. Adelman termed. Case reassigned to Judge Carol E. Jackson for all further proceedings. (KLH, ) (Entered: 07/20/2004)

ENTRY of Appearance by Michael J. Fagras Plaintiff Equal Employment Opportunity Commission. (Fagras, Michael) (Entered: 07/20/2004)

MOTION to Withdraw as Attorney ;attorney/firm Michael J. Fagras. (Fagras, Michael) (Entered: 07/22/2004)

ORDERED that attorney Michael Fagras' Motion to Withdraw his appearance as co-counsel for plaintiff 5 is granted. Attorney Michael J. Fagras terminated, notified by mail. Signed by Judge Carol E. Jackson on 7/27/04. (KLH, ) Modified on 7/27/2004 (KLH, ). (Entered: 07/27/2004)

Intervenor COMPLAINT JuryDemand,, filed by Ahmet Yigit Demerelli.(Fagras, Michael) (Entered: 08/10/2004)

ENTRY of Appearance by Mary M. Bonacorsi Defendant Convergys Customer Management Group, Inc.. (Bonacorsi, Mary) (Entered: 09/03/2004)

ANSWER AND AFFIRMATIVE DEFENSES to Complaint by Convergys Customer Management Group, Inc..(Jordan, Laura) Modified on 9/7/2004 (JMW, ), added the words "AND AFFIRMATIVE DEFENSES". (Entered: 09/03/2004)

DISCLOSURE OF CORPORATION INTERESTS CERTIFICATE by Defendant Convergys Customer Management Group, Inc. Parent companies: Convergys Corporation, Subsidiaries: None, Publicly held company: None,. (Jordan, Laura) (Entered: 09/03/2004)

ORDER this case shall be returned to the Clerk of the Court for reassignment to another District Judge. Signed by Judge Carol E. Jackson on 9/10/04. (LLW, ) (Entered: 09/10/2004)

ORDER REASSIGNING CASE (JGW). Case reassigned to Judge Charles A. Shaw for all further proceedings. Judge Carol E. Jackson no longer assigned to case pursuant to the Court's Order of this datesigned on 9/10/04. (LLW, ) (Entered: 09/10/2004)

RULE 16 ORDER This case is assigned to Track: 2. Joint Scheduling Plan due by 10/21/2004. Rule 16 Conference set for 11/5/2004 09:40 AM in Courtroom 12N before Honorable Charles A. Shaw. Signed by Judge Charles A. Shaw on 9/13/04. (KXS, ) (Entered: 09/13/2004)

JOINT SCHEDULING PLAN by Plaintiff Equal Employment Opportunity Commission. JOINT PROPOSED SCHEDULING PLAN . (Seely, Barbara) (Entered: 10/13/2004)

CASE MANAGEMENT ORDER This case is assigned to Track: standard Motion to Join Parties due by 12/20/2004. Discovery Completion due by 7/11/2005. ADR Future Reference 1/24/2005. Dispositive Motions due by 9/19/2005. Jury Trial set for 2/13/2006 09:00 AM before Honorable Charles A. Shaw. Pretrial Conference set for 2/9/2006 02:00 PM before Honorable Charles A. Shaw. Pretrial Compliance due by 1/25/2006.. Signed by Judge Charles A. Shaw on 11/5/04. (JWJ, ) (Entered: 11/05/2004)

Minute Entry for proceedings held before Judge Charles A. Shaw : Rule 16 Conference held on 11/5/2004. Parties present in person. Scheduling conference held in courtroom. Case management order to follow. (Court Reporter or FTR Gold Operator initials:none.) (FTR Gold yes or no: no.) (proceedings started: 9:49 am.) (proceedings ended: 9:56 am.) (MRC, ) (Entered: 11/08/2004)

MOTION to Intervene by Intervenor Plaintiff Ahmet Yigit Demerelli. (Fagras, Michael) (Entered: 11/16/2004)

MEMORANDUM AND ORDER IT IS HEREBY ORDERED that movant Ahmet Demerelli's mtn to intervene is GRANTED. (#17) IT IS FURTHER ORDERED that the Clerk of Court shall amend the caption of this case...IT IS FURTHER ORDERED that deft shall file its response to pltf/intervenor's complaint within 20 days of the date of this memorandum and order. Signed by Judge Charles A. Shaw on 12/10/04. (KXS, ) (Entered: 12/13/2004)

ANSWER to Intervenor Complaint Defendant by Convergys Customer Management Group, Inc..(Jordan, Laura) (Entered: 12/29/2004)

ORDER REFERRING CASE to Alternative Dispute Resolution. This case is referred to: Mediation Designation of Lead Counsel: Barbara A.Seely ADR Completion Deadline due by 3/25/2005. Designation of Neutral due by 2/8/2005. ADR Conference Schedule due by 2/8/2005.. Signed by Judge Charles A. Shaw on 1/24/2005. (MRC, ) (Entered: 01/24/2005)

Joint MOTION for Protective Order by Plaintiff Equal Employment Opportunity Commission. (Attachments: # 1)(Seely, Barbara) (Entered: 01/28/2005)

AGREED AND STIPULATED PROTECTIVE ORDER . Signed by Judge Charles A. Shaw on 2/1/05. (KXS, ) (Entered: 02/02/2005)

Designation of Neutral by parties and ADR Conference Report by Plaintiff Equal Employment Opportunity Commission Neutral: Charles Elbert Date of Conference: 03/16/05 time: 9:00 a.m. Location: Other(Seely, Barbara) (Entered: 03/16/2005)

NOTICE of Appointment of Neutral Neutral name: Charles Elbert, Neutral selected by parties, notice of appointment and order of referral mailed to Neutral Elbert.(SAC, ) (Entered: 03/16/2005)

ADR COMPLIANCE REPORT by Neutral: Charles Elbert, Date of Conference: March 16, 2005, participated in good faith: yes, the parties DID NOT achieve a settlement.(SAC, ) (Entered: 03/23/2005)

MOTION for Extension of Time to File ;Extension to file the following: Answers and Objections to Plaintiff's First Requests for Admissions, Fourth Interrogatories, and Sixth Request for Production of Documents ;Proposed extension date 5/16/2005 by Defendant Convergys Customer Management Group, Inc.. (Jordan, Laura) Modified on 4/25/2005 (JWJ, ). (Entered: 04/25/2005)

ORDER IT IS HEREBY ORDERED that defendant's motion for an extension of time to file answersand objections to discovery requests is GRANTED. [Doc. 26]IT IS FURTHER ORDERED that defendant shall provide to plaintiff its answers andobjections to plaintiff's First Requests for Admissions, Fourth Interrogatory Request, and SixthRequest for Production of Documents no later than May 16, 2005. Signed by Judge Charles A. Shaw on 4/28/05. (KXS, ) (Entered: 04/28/2005)

MOTION for Protective Order by Defendant Convergys Customer Management Group, Inc.. (Jordan, Laura) (Entered: 06/22/2005)

MEMORANDUM in Support of Motion re 28 MOTION for Protective Order filed by Defendant Convergys Customer Management Group, Inc.. (Attachments: # 1 Exhibit A-30(b)(6) Notice# 2 Exhibit B - EEOC's 5th Interrogatories# 3 Exhibit C-EEOC's 7th Request for Production# 4 Exhibit D - EEOC's 2nd Request for Admissions# 5 Exhibit E - Depo of T. Horstmann# 6 Exhibit F - Affidavit of Laura Jordan)(Jordan, Laura) (Entered: 06/22/2005)

MEMORANDUM in Opposition re 28 MOTION for Protective Order filed by Plaintiff Equal Employment Opportunity Commission. (Attachments: # 1 Exhibit 1# 2 Exhibit 2# 3 Exhibit 3# 4 Exhibit 4)(Seely, Barbara) (Entered: 07/01/2005)

ORDER IT IS HEREBY ORDERED that a hearing on defendant Convergys Customer ManagementGroup, Inc.'s motion for protective order is scheduled for Tuesday, July 12, 2005, at 9:30 a.m. inCourtroom 12-North. Signed by Judge Charles A. Shaw on 7/5/05. (KXS, ) (Entered: 07/05/2005)

ENTRY of Appearance by Erica L. Freeman Defendant Convergys Customer Management Group, Inc.. (Freeman, Erica) (Entered: 07/11/2005)

Minute Entry for proceedings held before Judge Charles A. Shaw : Motion Hearing held on 7/12/2005 re 28 MOTION for Protective Order filed by Convergys Customer Management Group, Inc.,. Hearing on deft's motion for protective order arguments heard. Motion is granted in part and denied in part. (Court Reporter or FTR Gold Operator initials:Lynn Shrum.) (FTR Gold yes or no: no.) (proceedings started: 9:45.) (proceedings ended: 10:15.) (JWJ, ) (Entered: 07/13/2005)

RESPONSE TO COURT ORDER re 28 MOTION for Protective Order by Defendant Convergys Customer Management Group, Inc.. (Attachments: # 1 Proposed Order)(Jordan, Laura) (Entered: 07/26/2005)

ORIGINAL TRANSCRIPT (Pilot) procedings of Hearing held on 7/12/05 before Judge Charles A. Shaw. Court Reporter: L. Shrum. The transcript filed with the court will not be remotely available until such time as the period for redaction has expired or a request for redaction has been received and the redacted transcript filed. For additional information see the Notice/Instructions to the Bar regarding Electronic Availability of Civil Transcripts on the Court's website at www.moed.uscourts.gov (KCM, ) (Entered: 07/26/2005)

MOTION for Leave to File Amended Answer by Defendant Convergys Customer Management Group, Inc.. (Jordan, Laura) (Entered: 09/06/2005)

AMENDED ANSWER to Plaintiff EEOC's Complaint by Defendant Convergys Customer Management Group, Inc.. (Jordan, Laura) Modified on 10/6/2005 (LGK, ). PURSUANT TO ORDER ENTERED 10/5/05 THIS DOCUMENT HAS BEEN DELETED. (Entered: 09/06/2005)

AMENDED ANSWER to Plaintiff-Intervener's Complaint by Defendant Convergys Customer Management Group, Inc.. (Jordan, Laura) Modified on 10/6/2005 (LGK, ). PURSUANT TO ORDER ENTERED 10/5/05 THIS DOCUMENT HAS BEEN DELETED. (Entered: 09/06/2005)

MOTION for Extension of Time to File ;Extension to file the following: Motion for Summary Judgment ;Proposed extension date September 30, 2005 by Defendant Convergys Customer Management Group, Inc.. (Jordan, Laura) (Entered: 09/07/2005)

ORDER IT IS HEREBY ORDERED that defendant's motion for an extension of time to file itsmotion for summary judgment is GRANTED. [Doc. 40]IT IS FURTHER ORDERED that the Case Management Order issued November 5, 2004,is modified as follows: (see order for further details). IT IS FURTHER ORDERED that except as modified herein, the provisions of the CaseManagement Order issued November 5, 2004, remain in full force and effect, particularly SectionII, Order Relating to Trial.Failure to comply with any part of this Order may result in the imposition of sanctions,including but not limited to dismissal of the action, entry of a default judgment or restrictionson the admissibility of certain evidence. See Local Rule 5.04. Dispositive Motions due by 9/30/2005. Signed by Judge Charles A. Shaw on 9/8/05. (KXS, ) (Entered: 09/08/2005)

MEMORANDUM in Opposition re 37 MOTION for Leave to File Amended Answer filed by Plaintiff Equal Employment Opportunity Commission. (Attachments: # 1 # 2 # 3 # 4)(Seely, Barbara) (Entered: 09/14/2005)

AMENDED MEMORANDUM in Opposition re 37 MOTION for Leave to File Amended Answer filed by Plaintiff Equal Employment Opportunity Commission. (Attachments: # 1 Exhibit 1# 2 Exhibit 2# 3 Exhibit 3# 4 Exhibit 4)(Seely, Barbara) Modified on 9/15/2005 (MRC, ). (Entered: 09/14/2005)

Defendant's Reply Memorandum In Support of Motion re 37 MOTION for Leave to File Amended Answer filed by Defendant Convergys Customer Management Group, Inc.. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Exhibit E# 6 Exhibit F# 7 Exhibit G# 8 Exhibit H# 9 Exhibit I# 10 Exhibit J)(Jordan, Laura) Modified on 9/26/2005 (MRC, ). [Document was filed as "Memorandum In Support of Motion" Docket Text Modified appropriately to reflect document filed.] (Entered: 09/23/2005)

ORDER - IT IS HEREBY ORDERED that plaintiff and plaintiff-intervenor's motion for oral argument on defendant's motion for leave to file an amended answer is DENIED. IT IS FURTHER ORDERED that plaintiff and plaintiff-intervenor's alternative motion for leave to file a sur-reply is GRANTED. IT IS FURTHER ORDERED that plaintiff and plaintiff-intervenor shall file any sur-reply no later than September 29, 2005 re 45 MOTION for Hearing, filed by Equal Employment Opportunity Commission, . Signed by Judge Charles A. Shaw on 9/28/2005. (MRC, ) (Entered: 09/28/2005)

SURREPLY to Motion re 37 MOTION for Leave to File Amended Answer filed by Plaintiff Equal Employment Opportunity Commission. (Seely, Barbara) (Entered: 09/29/2005)

MOTION for Summary Judgment by Defendant Convergys Customer Management Group, Inc.. (Jordan, Laura) (Entered: 09/30/2005)

MEMORANDUM in Support of Motion re 48 MOTION for Summary Judgment filed by Defendant Convergys Customer Management Group, Inc.. (Attachments: # 1 Exhibit A Part 1 of 3# 2 Exhibit A Part 2 of 3# 3 Exhibit A Part 3 of 3# 4 Exhibit B# 5 Exhibit C# 6 Exhibit D# 7 Exhibit E# 8 Exhibit F# 9 Exhibit G# 10 Exhibit H# 11 Exhibit I# 12 Exhibit J# 13 Exhibit K# 14 Exhibit L# 15 Exhibit M# 16 Exhibit N# 17 Exhibit O# 18 Exhibit P)(Jordan, Laura) (Entered: 09/30/2005)

MOTION for Leave to Submit Memorandum of Law in Support of Motion for Summary Judgment in Excess of Fifteen Pages by Defendant Convergys Customer Management Group, Inc.. (Jordan, Laura) (Entered: 09/30/2005)

MOTION for Partial Summary Judgment by Plaintiff Equal Employment Opportunity Commission. (Attachments: # 1 # 2 # 3 # 4 # 5 # 6 # 7 # 8 # 9 # 10 # 11 # 12 # 13 # 14 # 15 # 16 # 17 # 18 # 19 # 20 # 21 # 22 # 23 # 24 # 25)(Seely, Barbara) (Entered: 09/30/2005)

Docket Text ORDER re 50 MOTION for Leave to Submit Memorandum of Law in Support of Motion for Summary Judgment in Excess of Fifteen Pages by Defendant Convergys Customer Management Group, Inc. (Jordan, Laura) filed by Convergys Customer Management Group, Inc.; ORDERED GRANTED. Signed by Judge Charles A. Shaw on October 3, 2005. (EMW) (Entered: 10/03/2005)

MEMORANDUM AND ORDER re: 37 MOTION for Leave to File Amended Answer filed by Convergys Customer Management Group, Inc., motion is granted. FURTHER ORDERED that the Clerk of Court shall delete documents 38 and 39 from the record. FURTHER ORDERED that deft. Convergys Customer Management Group, Inc., shall file its answers to pltf. and pltf-intervenor's complaints no later than 10/11/05. Response to Court due by 10/11/2005.. Signed by Judge Charles A. Shaw on 10/5/05. (LGK, )

AMENDED ANSWER to Plaintiff-Intervener's Complaint by Defendant Convergys Customer Management Group, Inc.. (Jordan, Laura) (Entered: 10/06/2005)

MOTION for Leave to File in Excess of Page Limitation by Plaintiff Equal Employment Opportunity Commission. (Seely, Barbara) (Entered: 10/28/2005)

STATEMENT of Material Facts re 48 MOTION for Summary Judgment and Response to Defendant's Statement of Undisputed Facts filed by Plaintiff Equal Employment Opportunity Commission. (Attachments: # 1 Exhibit Deposition of Ahmet Demirelli# 2 Exhibit Village Square Office Lease# 3 Exhibit Deposition of Janet Gail Weaver# 4 Exhibit Affidavit of Donald G. Volmert# 5 Exhibit Deposition of Stephen Brookins# 6 Exhibit Counseling Record Form# 7 Exhibit Counseling Record Form# 8 Exhibit Deposition of Laura Ashton# 9 Exhibit Associate Guide# 10 Exhibit Deposition of Loretta Hill# 11 Exhibit Deposition of Teresa Horstmann# 12 Exhibit Affidavit of Yigit Demirelli# 13 Exhibit Deposition of Chester Moyer# 14 Exhibit Westlaw# 15 Exhibit Deposition of Tara Match# 16 Exhibit Deposition of Marlon D. Mitchell# 17 Exhibit Deposition of LaShonDa R. Aldridge# 18 Errata Counseling Record Form# 19 Exhibit Employee Schedule Exception Report# 20 Exhibit Counseling Record Form# 21 Exhibit Semi-Annual Performance Appraisal Worksheet# 22 Exhibit Written Appraisal of Performance Measurement# 23 Exhibit Transcript of Hearing Before the Honorable Charles A. Shaw# 24 Exhibit Deposition of Marsha Etheridge# 25 # 26 Exhibit Job Description# 27 Exhibit Site Plan# 28 Exhibit Associate Review# 29 Exhibit Counseling Record Form# 30 Exhibit Counseling Record Form# 31 Exhibit Counseling Record Form# 32 Exhibit Summary of Discussion with Yigit Demirreli# 33 Exhibit Employee Attendance Report# 34 Exhibit 365 day attendance record for tardies# 35 Exhibit Counseling Record Form# 36 Exhibit U.S. Department of Justice Immigration and Naturalization Service# 37 Exhibit Individual Schedules# 38 Exhibit Citizenship and Immigration Services)(Seely, Barbara) (Entered: 10/28/2005)

MEMORANDUM AND ORDER IT IS HEREBY ORDERED that plaintiff Equal Employment Opportunity Commission'smotion for leave to submit memorandum in opposition to defendant's motion for summary judgmentin excess of fifteen pages is GRANTED in part an d DENIED in part. [Doc. 55]IT IS FURTHER ORDERED that plaintiff shall file its memorandum in opposition todefendant's motion for summary judgement not to exceed 20 pages no later than Wednesday,November 2, 2005.IT IS FURTHER ORDERED that the Clerk of Court shall delete document 57 from therecord. Signed by Judge Charles A. Shaw on 10/31/05. (KXS, )

RESPONSE in Opposition re 51 MOTION for Partial Summary Judgment filed by Defendant Convergys Customer Management Group, Inc.. (Attachments: # 1 Exhibit 1# 2 Exhibit 2# 3 Exhibit 3# 4 Exhibit 4# 5 Exhibit 5)(Jordan, Laura) (Entered: 10/31/2005)

***REMARK - there will be no document #57 in this case; it has been deleted pursuant to an order entered 10/31/05 (KXS, ) (Entered: 10/31/2005)

REPLY to Response to Motion re 51 MOTION for Partial Summary Judgment filed by Plaintiff Equal Employment Opportunity Commission. (Attachments: # 1 Exhibit Counseling Record Form for Marc Jackson# 2 Exhibit Counseling Record Form for Joshua Caudle# 3 Exhibit Counseling Record Form for Lucretia Brown# 4 Exhibit Deposition of Marsha Etheridge - 8/31/05# 5 Exhibit Deposition of LaShonDa R. Aldridge - 3/4/05# 6 Exhibit Deposition of Stephen Brookins - 3/14/05# 7 Exhibit Transcript of Hearing Before The Honorable Charles A. Shaw - 7/12/05# 8 Exhibit Employee Attendance Report - Yigit Demirelli# 9 Exhibit Counseling Record Form -Yigit Demirelli)(Seely, Barbara) (Entered: 11/10/2005)

MOTION to Clarify by Defendant Convergys Customer Management Group, Inc.. (Jordan, Laura) (Entered: 11/10/2005)

Docket Text ORDER re 62 MOTION to Clarify by Defendant Convergys Customer Management Group, Inc.(Jordan, Laura) filed by Convergys Customer Management Group, Inc.; ORDERED GRANTED. IT IS HEREBY ORDERED that defendant's motion to clarify is GRANTED. IT IS FURTHER ORDERED that defendant shall file its reply in support of its motion for summary judgment no later than November 15, 2005. Signed by Judge Charles A. Shaw on November 10, 2005. (EMW) (Entered: 11/10/2005)

STATEMENT of Material Facts re 48 MOTION for Summary Judgment Reply filed by Defendant Convergys Customer Management Group, Inc.. (Attachments: # 1 Exhibit 1# 2 Exhibit 2# 3 Exhibit 3# 4 Exhibit 4# 5 Exhibit 5# 6 Exhibit 6# 7 Exhibit 7# 8 Exhibit 8)(Jordan, Laura) (Entered: 11/15/2005)

REPLY to Response to Motion re 48 MOTION for Summary Judgment filed by Defendant Convergys Customer Management Group, Inc.. (Jordan, Laura) (Entered: 11/15/2005)

MOTION for Leave to File Surreply to Defendant's Reply in Support of Motion for Summary Judgment by Plaintiff Equal Employment Opportunity Commission. (Seely, Barbara) (Entered: 11/16/2005)

SURREPLY to Motion re 48 MOTION for Summary Judgment filed by Plaintiff Equal Employment Opportunity Commission. (Attachments: # 1)(Seely, Barbara) (Entered: 11/17/2005)

Docket Text ORDER re 65 MOTION for Leave to File Surreply to Defendant's Reply in Support of Motion for Summary Judgment by Plaintiff Equal Employment Opportunity Commission. (Seely, Barbara) filed by Equal Employment Opportunity Commission; ORDERED GRANTED. IT IS HEREBY ORDERED that plaintiff's motion for leave to file a surreply is GRANTED. IT IS FURTHER ORDERED that plaintiff shall file its surreply no later than November 19, 2005.Signed by Judge Charles A. Shaw on November 17, 2005. (EMW) (Entered: 11/17/2005)

ORDER IT IS HEREBY ORDERED that defendant's motion for summary judgment is GRANTEDin part and DENIED in part as set forth in this memorandum and order. [Doc. 48]IT IS FURTHER ORDERED that plaintiff's motion for partial summary judgment isDENIED without prejudice. [Doc. 51] Signed by Judge Charles A. Shaw on 1/19/06. (JWJ, ) (Entered: 01/19/2006)

JUDGMENT (Partial) IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that partial judgment isGRANTED in favor of defendant Convergys Customer Management Group, Inc. and against plaintiffEqual Employment Opportunity Commission and plaintiff-intervenor Ahmet Yigit Demirelli onplaintiff's American with Disabilities Act claims that defendant failed to reasonably accommodate hisrequest for a parking space, to take a headset home, and to have an assigned seat.. Signed by Judge Charles A. Shaw on 1/19/06. (JWJ, ) (Entered: 01/19/2006)

MOTION to Alter Judgment by Plaintiff Equal Employment Opportunity Commission. (Attachments: # 1 # 2 Exhibit Exhibit 3 - Declaration of Tara Match)(Seely, Barbara) (Entered: 01/23/2006)

MOTION for Extension of Time to File ;Extension to file the following: Pretrial Materials ;Proposed extension date January 25, 2006 by Defendant Convergys Customer Management Group, Inc.. (Jordan, Laura) (Entered: 01/24/2006)

Exhibit List by Intervenor Plaintiff Ahmet Yigit Demerelli, Plaintiff Equal Employment Opportunity Commission.. (Seely, Barbara) (Entered: 01/25/2006)

Witness List by Intervenor Plaintiff Ahmet Yigit Demerelli, Plaintiff Equal Employment Opportunity Commission. (Seely, Barbara) (Entered: 01/25/2006)

Stipulation of Uncontested Facts by Intervenor Plaintiff Ahmet Yigit Demerelli, Plaintiff Equal Employment Opportunity Commission, Defendant Convergys Customer Management Group, Inc.. (Seely, Barbara) (Entered: 01/25/2006)

SUPPLEMENTAL re Docket Text Order, Plaintiffs' Designation of Deposition Testimony Proposed to be Offered Into Evidence by Intervenor Plaintiff Ahmet Yigit Demerelli, Plaintiff Equal Employment Opportunity Commission. (Seely, Barbara) (Entered: 01/25/2006)

Interrogatory Answer List by Intervenor Plaintiff Ahmet Yigit Demerelli, Plaintiff Equal Employment Opportunity Commission. (Seely, Barbara) (Entered: 01/25/2006)

Witness List by Defendant Convergys Customer Management Group, Inc.. (Jordan, Laura) (Entered: 01/25/2006)

Exhibit List by Defendant Convergys Customer Management Group, Inc... (Jordan, Laura) (Entered: 01/25/2006)

Deposition List by Defendant Convergys Customer Management Group, Inc.. (Jordan, Laura) (Entered: 01/25/2006)

Proposed Jury Instructions by Defendant Convergys Customer Management Group, Inc.. (Jordan, Laura) (Entered: 01/25/2006)

Proposed Voir Dire by Defendant Convergys Customer Management Group, Inc.. (Jordan, Laura) (Entered: 01/25/2006)

Proposed Jury Instructions by Intervenor Plaintiff Ahmet Yigit Demerelli, Plaintiff Equal Employment Opportunity Commission. (Seely, Barbara) (NOTE: document deleted per order entered 3/9/06; attorney to refile corrected document) Modified on 3/10/2006 (KXS, ). (Entered: 01/25/2006)

Proposed Jury Instructions by Intervenor Plaintiff Ahmet Yigit Demerelli, Plaintiff Equal Employment Opportunity Commission. (Seely, Barbara) (NOTE: document deleted per order entered 3/9/06; attorney to refile corrected document) Modified on 3/10/2006 (KXS, ). (Entered: 01/25/2006)

Docket Text ORDER re 70 MOTION for Extension of Time to File; Extension to file the following: Pretrial Materials; Proposed extension date January 25, 2006 by Defendant Convergys Customer Management Group, Inc. (Jordan, Laura) filed by Convergys Customer Management Group, Inc.; ORDERED GRANTED. Signed by Judge Charles A. Shaw on January 25, 2006. (EMW) (Entered: 01/25/2006)

MOTION for Extension of Time to File Proposed Jury Instructions with Citations by Intervenor Plaintiff Ahmet Yigit Demerelli, Plaintiff Equal Employment Opportunity Commission. (Attachments: # 1)(Seely, Barbara) (Entered: 01/26/2006)

SCHEDULING ORDER: ORDERED that the trial setting of 2/13/06 is vacated. Jury Trial reset for 3/20/2006 09:00 AM in Courtroom 12N before Honorable Charles A. Shaw. Pretrial Conference reset for 3/16/2006 02:00 PM in Courtroom 12N before Honorable Charles A. Shaw.. Signed by Judge Charles A. Shaw on 12/26/06. (LGK, ) (Entered: 01/26/2006)

Proposed Jury Instructions (with citations) by Intervenor Plaintiff Ahmet Yigit Demerelli, Plaintiff Equal Employment Opportunity Commission. (MRC, ) (NOTE: document deleted per order entered 3/9/06; attorney to refile corrected document) Modified on 3/10/2006 (KXS, ). (Entered: 01/30/2006)

Docket Text ORDER re 84 MOTION for Extension of Time to File Proposed Jury Instructions with Citations by Intervenor Plaintiff Ahmet Yigit Demerelli, Plaintiff Equal Employment Opportunity Commission. (Attachments: # )(Seely, Barbara) filed by Equal Employment Opportunity Commission, Ahmet Yigit Demerelli; ORDERED GRANTED. Signed by Judge Charles A. Shaw on January 27, 2006. (EMW) (Entered: 01/27/2006)

MOTION for Extension of Time to File Response/Reply as to 69 MOTION to Alter Judgment by Defendant Convergys Customer Management Group, Inc.. (Jordan, Laura) (Entered: 01/30/2006)

Joint MOTION to Continue Trial Setting by Defendant Convergys Customer Management Group, Inc.. (Jordan, Laura) (Entered: 01/31/2006)

Docket Text ORDER re 87 MOTION for Extension of Time to File Response/Reply as to 69 MOTION to Alter Judgment by Defendant Convergys Customer Management Group, Inc. (Jordan, Laura) filed by Convergys Customer Management Group, Inc.; ORDERED GRANTED. IT IS HEREBY ORDERED that defendant's motion for an extension of time to respond to plaintiff's motion to alter or amend judgment is GRANTED. IT IS FURTHER ORDERED that defendant shall file its response to plaintiff's motion to alter or amend judgment no later than February 6, 2006. Signed by Judge Charles A. Shaw on January 31, 2006. (EMW) (Entered: 01/31/2006)

ORDER AMENDING CASE MANAGEMENT ORDER IT IS HEREBY ORDERED that the parties' joint motion for continuance is GRANTED.[Doc. 88]IT IS FURTHER ORDERED that the Case Management Order of November 5, 2004 andmodified on September 8, 2005 is modified as follows: Jury Trial set for 4/10/2006 09:00 AM in Courtroom 12N before Honorable Charles A. Shaw. Pretrial Conference set for 4/6/2006 02:00 PM in Courtroom 12N before Honorable Charles A. Shaw. Signed by Judge Charles A. Shaw on 2/2/06. (KXS, ) (Entered: 02/02/2006)

RESPONSE in Opposition re 69 MOTION to Alter Judgment filed by Defendant Convergys Customer Management Group, Inc.. (Jordan, Laura) (Entered: 02/06/2006)

MOTION to Withdraw 86 Proposed Jury Instructions, 82 Proposed Jury Instructions, 83 Proposed Jury Instructions by Plaintiff Equal Employment Opportunity Commission. (Seely, Barbara) (Entered: 03/07/2006)

MOTION to Withdraw as Attorney ;attorney/firm Donna L. Harper by Intervenor Plaintiff Ahmet Yigit Demerelli, Plaintiff Equal Employment Opportunity Commission. (Harper, Donna) (Entered: 03/08/2006)

ORDER IT IS HEREBY ORDERED that plaintiffs' motion to withdraw jury instructions isGRANTED. [Doc. 91]IT IS FURTHER ORDERED that the Clerk of Court shall delete documents 82, 83, and86 from the record.IT IS FURTHER ORDERED that plaintiffs shall file their corrected jury instructions nolater than March 13, 2006. Signed by Judge Charles A. Shaw on 3/9/06. (KXS, ) (Entered: 03/09/2006)

Docket Text ORDER re 92 MOTION to Withdraw as Attorney; attorney/firm Donna L. Harper by Intervenor Plaintiff Ahmet Yigit Demerelli, Plaintiff Equal Employment Opportunity Commission. (Harper, Donna) filed by Equal Employment Opportunity Commission,Ahmet Yigit Demerelli; ORDERED GRANTED. Signed by Judge Charles A. Shaw on March 9, 2006. (EMW) (Entered: 03/09/2006)

Proposed Jury Instructions by Plaintiff Equal Employment Opportunity Commission. (Seely, Barbara) (Entered: 03/10/2006)

Proposed Jury Instructions by Plaintiff Equal Employment Opportunity Commission. (Seely, Barbara) (Entered: 03/10/2006)

MOTION in Limine To Exclude Evidence that Demirelli Lacked Employment Authorization from September 10, 2001 Through April 4, 2002 by Intervenor Plaintiff Ahmet Yigit Demerelli, Plaintiff Equal Employment Opportunity Commission. (Attachments: # 1 # 2 # 3 # 4)(Seely, Barbara) (Entered: 03/31/2006)

MOTION in Limine To Exclude Evidence of Additional Tardies Or, In The Alternative, For A Limiting Instruction by Intervenor Plaintiff Ahmet Yigit Demerelli, Plaintiff Equal Employment Opportunity Commission. (Attachments: # 1 # 2 # 3 # 4 # 5 # 6 # 7 # 8 # 9 # 10 # 11 # 12)(Seely, Barbara) (Entered: 03/31/2006)

MOTION in Limine To Exclude Evidence Of No Call/No Show by Intervenor Plaintiff Ahmet Yigit Demerelli, Plaintiff Equal Employment Opportunity Commission. (Attachments: # 1 # 2)(Seely, Barbara) (Entered: 03/31/2006)