Case: EEOC v. Paramount Staffing

2:06-cv-02624 | U.S. District Court for the Western District of Tennessee

Filed Date: Sept. 22, 2006

Closed Date: Aug. 19, 2010

Clearinghouse coding complete

Case Summary

The Memphis Office of the EEOC brought this suit against Paramount Staffing, Inc. in September 2006 in the United States District Court for the Western District of Tennessee (Memphis). The complaint alleged discrimination and retaliation based on race (African American) and national origin (American). The case was assigned to Judge John Phipps McCalla and Magistrate Diane K. Vescovo, and was later transferred to Magistrate Judge Gerald B. Cohn. The defendant moved for Summary Judgement in July…

The Memphis Office of the EEOC brought this suit against Paramount Staffing, Inc. in September 2006 in the United States District Court for the Western District of Tennessee (Memphis). The complaint alleged discrimination and retaliation based on race (African American) and national origin (American). The case was assigned to Judge John Phipps McCalla and Magistrate Diane K. Vescovo, and was later transferred to Magistrate Judge Gerald B. Cohn.

The defendant moved for Summary Judgement in July 2008. In March 2009, Magistrate Judge Cohn denied the Summary Judgment motion and set a date for jury trial. 601 F.Supp.2d 986, 2009 WL 593729. The parties then proceeded to prepare for trial through 2009 and litigated discovery.

On August 9, 2010, the parties reached a settlement. The parties entered into a consent decree 10 days later on August 19, 2010. The consent decree was not an admission of liability by the defendant; but the defendant was enjoined from discriminatory hiring practices on the basis of race. The decree also contained provisions for the defendant to hire an expert to develop and implement a fair hiring policy and awareness training, submit three reports to the EEOC, and award $585,000 in damages to the plaintiff and all eligible class members. The consent decree was in effect for two years from the date of entry. The case was dismissed with prejudice.

Summary Authors

Daisy Manning (6/5/2008)

Chelsea Rinnig (3/24/2018)

People

For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/4384142/parties/equal-employment-opportunity-commission-v-paramount-staffing-inc/


Judge(s)

Claxton, Charmiane G. (Tennessee)

Cohn, Gerald B. (Illinois)

McCalla, Jon Phipps (Tennessee)

Attorneys(s) for Plaintiff

Beck, Terry (Tennessee)

Cooper, Ronald S. (Tennessee)

Dills, Steven W. (Tennessee)

Johnson, Johnnie L. III (Tennessee)

Lee, James (Tennessee)

Ramsey, Sally (Tennessee)

Reams, Gwendolyn Young (Tennessee)

Judge(s)

Claxton, Charmiane G. (Tennessee)

Cohn, Gerald B. (Illinois)

McCalla, Jon Phipps (Tennessee)

Attorneys(s) for Plaintiff

Beck, Terry (Tennessee)

Cooper, Ronald S. (Tennessee)

Dills, Steven W. (Tennessee)

Johnson, Johnnie L. III (Tennessee)

Lee, James (Tennessee)

Ramsey, Sally (Tennessee)

Reams, Gwendolyn Young (Tennessee)

Smith, Deidre (Tennessee)

Williams, Faye A. (Tennessee)

Attorneys(s) for Defendant

Adams, Sylvia R. (Tennessee)

Canale, Brenda Nelson (Tennessee)

Hymowitz, Steven (Tennessee)

Loveland, George W. II (Tennessee)

Nelson, Brenda R. (Tennessee)

Prather, Paul E. (Tennessee)

Documents in the Clearinghouse

Document

Docket (PACER)

Equal Employment Opportunity Commission v. Paramount Staffing, Inc.

Aug. 19, 2010 Docket
1-1

Complaint

Equal Employment Opportunity Commission v. Paramount Staffing, Inc.

Sept. 22, 2006 Complaint
29

Order Denying Defendant's Motion to Compel

EEOC v. Paramount Staffing, Inc.

2008 WL 11318300

June 25, 2008 Order/Opinion
30

Order Granting Defendant's Motion for Protective Order

EEOC v. Paramount Staffing, Inc.

July 14, 2008 Order/Opinion
34

Order Granting Joint Motion for Protective Order

EEOC v. Paramount Staffing, Inc.

Sept. 3, 2008 Order/Opinion
50

Order Denying Defendant's Motion for Summary Judgment Based Upon EEOC's Failure to Conciliate in Good Faith

EEOC v. Paramount Staffing, Inc.

601 F.Supp.2d 986

March 9, 2009 Order/Opinion
117

Consent Decree

EEOC v. Paramount Staffing, Inc.

Aug. 19, 2010 Order/Opinion

Docket

See docket on RECAP: https://www.courtlistener.com/docket/4384142/equal-employment-opportunity-commission-v-paramount-staffing-inc/

Last updated May 12, 2022, 8 p.m.

ECF Number Description Date Link
1

COMPLAINT against Paramount Staffing, Inc. (Filing fee $350.00 waived), filed by Equal Employment Opportunity Commission. (Attachments: # 1 Civil Cover Sheet)(cas) (Entered: 09/22/2006)

1 Civil Cover Sheet

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Sept. 22, 2006 RECAP
2

ANSWER to Complaint by Paramount Staffing, Inc..(Prather, Paul) (Entered: 12/29/2006)

Dec. 29, 2006 PACER
3

NOTICE of Appearance by Johnnie L. Johnson, III on behalf of Equal Employment Opportunity Commission (Johnson, Johnnie) (Entered: 01/10/2007)

Jan. 10, 2007 PACER
4

Notice of Correction to 3 Notice of Appearance to correct inadvertent omission of Terry Beck. (Attachments: # 1 Corrected Notice of Appearance)(Johnson, Johnnie) (Entered: 01/11/2007)

1 Corrected Notice of Appearance

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Jan. 11, 2007 PACER
5

SETTING LETTER: Scheduling Conference set for 2/26/2007 09:30 AM in Courtroom 5 - Memphis before Judge Jon Phipps McCalla. Please email the proposed joint scheduling order to ECF_Judge_Vescovo@tnwd.uscourts.gov by Tuesday, February 20, 2007. If the order is approved and filed, the conference will be canceled.Please see Judge Vescovo's Rule 16(b) instructions at www.tnwd.uscourts.gov under Instructions, Procedures and Attachments to Notices.(crv) (Entered: 02/08/2007)

Feb. 8, 2007 PACER
6

CORPORATE DISCLOSURE STATEMENT filed by Paramount Staffing, Inc. listing corporate parent as no parent company. (Prather, Paul) (Entered: 02/16/2007)

Feb. 16, 2007 PACER
7

SCHEDULING ORDER -- Entry of this order cancels the scheduling conference set 2/26/2007. Signed by Magistrate Judge Diane K. Vescovo on 2/22/2007. (Vescovo, Diane) Additional attachment(s) added on 2/23/2007 (crv, ). (Entered: 02/22/2007)

Feb. 22, 2007 PACER
8

NOTICE of Appearance by George W. Loveland, II on behalf of Paramount Staffing, Inc. (Loveland, George) (Entered: 03/15/2007)

March 15, 2007 PACER
9

MOTION to Substitute Attorney Proposed Order Submitted by Equal Employment Opportunity Commission. (Ramsey, Sally) (Entered: 09/17/2007)

Sept. 17, 2007 PACER
10

PLAINTIFF EQUAL EMPLOYMENT OPPORTUNITY COMMISSIONS ORDER ON MOTION TO SUBSTITUTE COUNSEL. Signed by Judge Jon Phipps McCalla on 9/20/07. (McCalla, Jon) (Entered: 09/20/2007)

Sept. 20, 2007 PACER
11

MOTION to Withdraw as Attorney (Proposed Order Submitted) by Equal Employment Opportunity Commission. (Smith, Deidre) (Entered: 01/09/2008)

Jan. 9, 2008 PACER
12

ORDER granting 11 Motion to Withdraw as Attorney. Attorney Terry L. Beck terminated. Signed by Chief Judge Jon Phipps McCalla on 1/9/08. (McCalla, Jon) (Entered: 01/10/2008)

Jan. 10, 2008 PACER
13

MOTION to Amend/Correct 7 Scheduling Order (Proposed Order submitted) by Equal Employment Opportunity Commission. (Attachments: # 1 Memorandum in Support, # 2 Certificate of Consultation)(Smith, Deidre) (Entered: 02/07/2008)

1 Memorandum in Support

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2 Certificate of Consultation

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Feb. 7, 2008 PACER
14

ORDER granting 13 PLAINTIFF'S UNOPPOSED MOTION TO MODIFY RULE 16(b) SCHEDULING ORDER. Signed by Chief Judge Jon Phipps McCalla on 2/8/08. (McCalla, Jon) (Entered: 02/08/2008)

Feb. 8, 2008 PACER
15

Second MOTION MOdify Rule 16(b) Scheduling Order re 7 Scheduling Order (Proposed Order Submitted) by Equal Employment Opportunity Commission. (Attachments: # 1 Memorandum in Support of Motion to Modify Scheduling Order, # 2 Exhibit No. 1 - Smith letter, dated 2-27-08, # 3 Exhibit No. 2- Loveland letter, dated 3-25-08, # 4 Exhibit No. 3 - Loveland letter, dated 4-7-08, # 5 Exhibit Lov eland letter, dated 4-9-08, # 6 Exhibit No. 5 - Unreported Case - Sloan v. Cattron, Inc., # 7 Exhibit No. 6 - Unreported Case - Davis v. Runyon, # 8 Exhibit No. 7 - Cardenas depo excerpts)(Smith, Deidre) (Entered: 05/13/2008)

1 Memorandum in Support of Motion to Modify Scheduling Order

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2 Exhibit No. 1 - Smith letter, dated 2-27-08

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3 Exhibit No. 2- Loveland letter, dated 3-25-08

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4 Exhibit No. 3 - Loveland letter, dated 4-7-08

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5 Exhibit Lov eland letter, dated 4-9-08

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6 Exhibit No. 5 - Unreported Case - Sloan v. Cattron, Inc.

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7 Exhibit No. 6 - Unreported Case - Davis v. Runyon

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8 Exhibit No. 7 - Cardenas depo excerpts

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May 13, 2008 PACER
16

DEFICIENCY NOTICE: Pursuant to Rule 5 of the Federal Rules of Civil Procedure, document 15 Second MOTION MOdify Rule 16(b) Scheduling Order re 7 Scheduling Order (Proposed Order Submitted) filed by Equal Employment Opportunity Commission has been filed. However, the following deficiency has been found: Filer did not include a certificate of consultation with the motion. Filer should submit certificate under "Other documents - Attachments" allowing filer to link this document to entry # 15. The filer has one business day to correct the deficiency. (jae, ) Modified on 5/15/2008 to remove duplicate wording(jae, ). (Entered: 05/14/2008)

May 14, 2008 PACER
17

ATTACHMENT Certificate of Consultation (inadvertently omitted from filing) to 15 Second MOTION MOdify Rule 16(b) Scheduling Order re 7 Scheduling Order (Proposed Order Submitted)Second MOTION MOdify Rule 16(b) Scheduling Order re 7 Scheduling Order (Proposed Order Submitted) by Equal Employment Opportunity Commission. (Dills, Steven) Modified on 5/15/2008 to remove duplicate wording (jae, ). (Entered: 05/14/2008)

May 14, 2008 PACER
18

MOTION for Protective Order proposed Order submitted by Paramount Staffing, Inc.. (Attachments: # 1 Memorandum in Support of Motion for Protective Order, # 2 Certificate of Consultation)(Loveland, George) (Entered: 05/16/2008)

1 Memorandum in Support of Motion for Protective Order

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2 Certificate of Consultation

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May 16, 2008 PACER
19

ORDER REFERRING MOTION FOR DETERMINATION: 18 MOTION for Protective Order filed by Paramount Staffing, Inc. Signed by Chief Judge Jon Phipps McCalla on 5/19/08. (McCalla, Jon) (Entered: 05/19/2008)

May 19, 2008 PACER
20

NOTICE of Appearance by Steven W. Dills on behalf of Equal Employment Opportunity Commission (Dills, Steven) (Entered: 05/22/2008)

May 22, 2008 PACER
21

COURTESY NOTICE: Pursuant to Rule 5 of the Federal Rules of Civil Procedure, document 20 Notice of Appearance filed by Equal Employment Opportunity Commission has been filed. For future reference, please note : In order to receive the notice of electronic filing (NEF), when submitting a notice of appearance, be sure that you select "Yes" to "Notice". Clerk's office has corrected the filing and attorney Steven Dills should now be noticed on all filings. Filer is not required to resubmit document. (jae, ) (Entered: 05/23/2008)

May 23, 2008 PACER
22

MOTION to Compel by Paramount Staffing, Inc.. (Attachments: # 1 Memorandum in Support of Motion to Compel, # 2 Exhibit 1 - January 23, 2008 letter, # 3 Exhibit 2 February 7, 2008 letter, # 4 Exhibit 3 February 22, 2008 letter, # 5 Exhibit 4 March 4, 2008 letter, # 6 Exhibit 5 March 12 letter, # 7 Exhibit 6 March 19, 2008 letter, # 8 Exhibit 7 March 20, 2008 letter, # 9 Exhibit 8 March 27, 2008 letter, # 10 Exhibit 9 March 28, 2008 letter, # 11 Exhibit 10 April 9, 2008 letter, # 12 Exhibit 11 April 25, 2008 letter, # 13 Exhibit 12 May 9 letter, # 14 Exhibit 13 May 19, 2008 letter, # 15 Exhibit 14 May 21, 2008 letter, # 16 Exhibit 15 May 21, 2008 letter, # 17 Certificate of Consultation)(Loveland, George) (Entered: 05/23/2008)

1 Memorandum in Support of Motion to Compel

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2 Exhibit 1 - January 23, 2008 letter

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3 Exhibit 2 February 7, 2008 letter

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4 Exhibit 3 February 22, 2008 letter

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5 Exhibit 4 March 4, 2008 letter

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6 Exhibit 5 March 12 letter

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7 Exhibit 6 March 19, 2008 letter

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8 Exhibit 7 March 20, 2008 letter

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9 Exhibit 8 March 27, 2008 letter

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10 Exhibit 9 March 28, 2008 letter

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11 Exhibit 10 April 9, 2008 letter

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12 Exhibit 11 April 25, 2008 letter

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13 Exhibit 12 May 9 letter

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14 Exhibit 13 May 19, 2008 letter

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15 Exhibit 14 May 21, 2008 letter

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16 Exhibit 15 May 21, 2008 letter

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17 Certificate of Consultation

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May 23, 2008 PACER
23

RESPONSE in Opposition re 15 Second MOTION MOdify Rule 16(b) Scheduling Order re 7 Scheduling Order (Proposed Order Submitted)Second MOTION MOdify Rule 16(b) Scheduling Order re 7 Scheduling Order (Proposed Order Submitted)Second MOTION MOdify Rule 16(b) Scheduling Order re 7 Scheduling Order (Proposed Order Submitted) filed by Paramount Staffing, Inc.. (Attachments: # 1 Exhibit, # 2 Exhibit)(Loveland, George) (Entered: 05/28/2008)

1 Exhibit

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2 Exhibit

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May 28, 2008 PACER
24

ORDER REFERRING MOTION FOR DETERMINATION: 22 MOTION to Compel filed by Paramount Staffing, Inc. Signed by Chief Judge Jon Phipps McCalla on 5/28/08. (McCalla, Jon) (Entered: 05/28/2008)

May 28, 2008 PACER
25

RESPONSE in Opposition re 18 MOTION for Protective Order proposed Order submitted (Proposed Order Submitted) filed by Equal Employment Opportunity Commission. (Attachments: # 1 Memorandum in Support of Plaintiff's Response in Opposition to Defendant's Motion for Protective Order, # 2 Exhibit No. 1 - Letter to Loveland, dated 4-7-08, # 3 Exhibit No. 2 - Paramount Press Release, dated 8-3-06)(Dills, Steven) (Entered: 06/02/2008)

1 Memorandum in Support of Plaintiff's Response in Opposition to Defendant�

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2 Exhibit No. 1 - Letter to Loveland, dated 4-7-08

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3 Exhibit No. 2 - Paramount Press Release, dated 8-3-06

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June 2, 2008 PACER
26

RESPONSE in Opposition re 22 MOTION to Compel (Proposed Order Submitted) filed by Equal Employment Opportunity Commission. (Attachments: # 1 Memorandum in Support of Response in Opposition, # 2 Exhibit No. 1 - Unpublished Case - EEOC v. Grace Episcopal Churdh, # 3 Exhibit No. 2 - Unpublished Case - EEOC v. Venator Group, # 4 Exhibit No. 3 - Cardenas deposition excerpts)(Dills, Steven) (Entered: 06/09/2008)

1 Memorandum in Support of Response in Opposition

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2 Exhibit No. 1 - Unpublished Case - EEOC v. Grace Episcopal Churdh

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3 Exhibit No. 2 - Unpublished Case - EEOC v. Venator Group

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4 Exhibit No. 3 - Cardenas deposition excerpts

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June 9, 2008 PACER
27

ORDER granting 15 PLAINTIFF'S MOTION TO MODIFY RULE 16(b) SCHEDULING ORDER. Signed by Chief Judge Jon Phipps McCalla on 6/10/08. (McCalla, Jon) (Entered: 06/10/2008)

June 10, 2008 PACER
28

ORDER OF TRANSFER. Signed by Magistrate Judge Diane K. Vescovo on 6/16/2008. (Vescovo, Diane) (Entered: 06/16/2008)

June 16, 2008 PACER
29

ORDER denying 22 Motion to Compel. Signed by Magistrate Judge Gerald B. Cohn on 6/25/2008. (Cohn, Gerald) (Entered: 06/25/2008)

June 25, 2008 PACER
30

ORDER granting 18 Motion for Protective Order. Signed by Magistrate Judge Gerald B. Cohn on 7/14/2008. (Cohn, Gerald) (Entered: 07/14/2008)

July 14, 2008 PACER
31

MOTION for Summary Judgment [Proposed] Order and Documents Submitted by Paramount Staffing, Inc.. (Attachments: # 1 Memorandum Memo in Support of Motion for Summary Judgment, # 2 Exhibit Exhibit 1 - Memo in Support of Motion for Summary Judgment, # 3 Exhibit Exhibit 2 - Memo in Support of Motion for Summary Judgment, # 4 Exhibit Exhibit 3 - Memo in Support of Motion for Summary Judgment, # 5 Exhibit Exhibit 4 - Memo in Support of Motion for Summary Judgment)(Prather, Paul) (Entered: 08/22/2008)

1 Memorandum Memo in Support of Motion for Summary Judgment

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2 Exhibit Exhibit 1 - Memo in Support of Motion for Summary Judgment

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3 Exhibit Exhibit 2 - Memo in Support of Motion for Summary Judgment

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4 Exhibit Exhibit 3 - Memo in Support of Motion for Summary Judgment

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5 Exhibit Exhibit 4 - Memo in Support of Motion for Summary Judgment

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Aug. 22, 2008 PACER
32

Joint MOTION for Protective Order by all parties. (Attachments: # 1 Exhibit A-Agreed Protective Order)(Prather, Paul) (Entered: 08/27/2008)

1 Exhibit A-Agreed Protective Order

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Aug. 27, 2008 PACER
33

DEFICIENCY NOTICE: Pursuant to Rule 5 of the Federal Rules of Civil Procedure, document 32 Joint MOTION for Protective Order filed by Equal Employment Opportunity Commission, Paramount Staffing, Inc. has been filed. However, the following deficiency has been found: Proposed orders should be emailed to chambers, not published to CM/ECF. The filer has one business day to correct the deficiency. (jae) (Entered: 08/28/2008)

Aug. 28, 2008 PACER
34

ORDER granting JOINT MOTION FOR PROTECTIVE ORDER. Signed by Chief Judge Jon Phipps McCalla on 9/03/08. (McCalla, Jon) (Entered: 09/03/2008)

Sept. 3, 2008 PACER
35

Joint MOTION to Modify Rule 16(b) Scheduling Order (Proposed Order submitted) by Equal Employment Opportunity Commission. (Attachments: # 1 Memorandum in Support)(Smith, Deidre) (Entered: 09/16/2008)

1 Memorandum in Support

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Sept. 16, 2008 PACER
36

ORDER GRANTING JOINT MOTION TO MODIFY RULE 16(b) SCHEDULING ORDER. Signed by Chief Judge Jon Phipps McCalla on 09/16/08. (McCalla, Jon) (Entered: 09/16/2008)

Sept. 16, 2008 PACER
37

SETTING LETTER: Telephonic Hearing re: 31 Defendants Motion for Summary Judgment Based Upon EEOCs Failure to Conciliate in Good Faith set for 11/19/2008 03:00 PM before Chief Judge Jon Phipps McCalla. (jpw) (Entered: 09/17/2008)

Sept. 17, 2008 PACER
38

RESPONSE in Opposition re 31 MOTION for Summary Judgment [Proposed] Order and Documents Submitted filed by Equal Employment Opportunity Commission. (Attachments: # 1 Memorandum in Support, # 2 Affidavit of Deidre Smith)(Dills, Steven) (Entered: 09/22/2008)

1 Memorandum in Support

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2 Affidavit of Deidre Smith

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Sept. 22, 2008 PACER
39

MOTION for Leave to File [Proposed] Order Submitted by Paramount Staffing, Inc.. (Attachments: # 1 Memorandum Memo in Support of Defendant's Motion for Leave to File Reply, # 2 Certificate of Consultation Certificate of Consultation)(Prather, Paul) (Entered: 10/14/2008)

1 Memorandum Memo in Support of Defendant's Motion for Leave to File Reply

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2 Certificate of Consultation Certificate of Consultation

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Oct. 14, 2008 PACER
40

ORDER SETTING TRIAL AND PRETRIAL DATES. Signed by Chief Judge Jon Phipps McCalla on 10/16/08. (McCalla, Jon) (Entered: 10/16/2008)

Oct. 16, 2008 PACER
41

SETTING LETTER: Jury Trial set for 9/28/2009 09:30 AM in Courtroom 1 - Memphis before Chief Judge Jon Phipps McCalla. Pretrial Conference set for 9/22/2008 08:45 AM in Courtroom 1 - Memphis before Chief Judge Jon Phipps McCalla. Proposed Pretrial Order due by 4:30 PM on 9/15/2009. (jpw) (Entered: 10/17/2008)

Oct. 17, 2008 PACER
42

MOTION to Amend/Correct 37 Setting Letter Proposed Order Submitted by Paramount Staffing, Inc.. (Attachments: # 1 Certificate of Consultation Certificate of Consultation)(Nelson, Brenda) (Entered: 10/17/2008)

1 Certificate of Consultation Certificate of Consultation

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Oct. 17, 2008 PACER
43

ORDER granting 39 DEFENDANT'S MOTION FOR LEAVE TO FILE REPLY. Signed by Chief Judge Jon Phipps McCalla on 11/18/08. (McCalla, Jon) (Entered: 11/18/2008)

Nov. 18, 2008 PACER
44

ORDER denying as moot 42 DEFENDANT'S MOTION TO AMEND/CORRECT SETTING LETTER. Signed by Chief Judge Jon Phipps McCalla on 11/18/08. (McCalla, Jon) (Entered: 11/18/2008)

Nov. 18, 2008 PACER
45

REPLY to Response to Motion re 31 MOTION for Summary Judgment [Proposed] Order and Documents Submitted filed by Paramount Staffing, Inc.. (Prather, Paul) (Entered: 11/26/2008)

Nov. 26, 2008 PACER
46

MOTION to Amend/Correct 7 Scheduling Order proposed order submitted by Paramount Staffing, Inc.. (Attachments: # 1 Certificate of Consultation)(Prather, Paul) (Entered: 02/20/2009)

1 Certificate of Consultation

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Feb. 20, 2009 PACER
47

ORDER granting 46 Motion to Amend/Correct. Signed by Chief Judge Jon Phipps McCalla on 2/23/09. (McCalla, Jon) (Entered: 02/23/2009)

Feb. 23, 2009 PACER
48

AMENDED ORDER GRANTING DEFENDANT'S UNOPPOSED MOTION TO AMEND RULE 16(b) SCHEDULING ORDER. Signed by Chief Judge Jon Phipps McCalla on 2/24/09. (McCalla, Jon) (Entered: 02/24/2009)

Feb. 24, 2009 PACER
49

SETTING LETTER: Jury Trial reset for 11/16/2009 09:30 AM in Courtroom 1 - Memphis before Chief Judge Jon Phipps McCalla. Pretrial Conference reset for 11/6/2009 09:00 AM in Courtroom 1 - Memphis before Chief Judge Jon Phipps McCalla. Proposed Pretrial Order due by 10/30/2009. (jpw) (Entered: 02/24/2009)

Feb. 24, 2009 PACER
50

ORDER denying 31 Motion for Summary Judgment. Signed by Chief Judge Jon Phipps McCalla on 3/9/09. (McCalla, Jon) (Entered: 03/09/2009)

March 9, 2009 PACER
51

MOTION for Protective Order (Proposed Protective Order submitted) by Equal Employment Opportunity Commission. (Attachments: # 1 Memorandum in Support of Motion for Protective Order or Motion to Quash Subpoena, # 2 Exhibit A - Sharp Subpoena(s), # 3 Exhibit B - Schmitt Subpoena, # 4 Exhibit C - Nelson April 6 Letter, # 5 Exhibit D - Sharp April 7 Letter, # 6 Exhibit E- Smith Declaration, # 7 Exhibit F - Sharp Declaration, # 8 Certificate of Consultation)(Smith, Deidre) (Entered: 04/09/2009)

1 Memorandum in Support of Motion for Protective Order or Motion to Quash Subpoena

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2 Exhibit A - Sharp Subpoena(s)

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3 Exhibit B - Schmitt Subpoena

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4 Exhibit C - Nelson April 6 Letter

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5 Exhibit D - Sharp April 7 Letter

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6 Exhibit E- Smith Declaration

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7 Exhibit F - Sharp Declaration

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8 Certificate of Consultation

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April 9, 2009 PACER
52

ORDER REFERRING MOTION: 51 MOTION for Protective Order (Proposed Protective Order submitted) filed by Equal Employment Opportunity Commission. Signed by Chief Judge Jon Phipps McCalla on 4/13/09. (McCalla, Jon) (Entered: 04/13/2009)

April 13, 2009 PACER
53

RESPONSE in Opposition re 51 MOTION for Protective Order (Proposed Protective Order submitted) filed by Paramount Staffing, Inc.. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Exhibit, # 5 Exhibit)(Nelson, Brenda) (Entered: 04/27/2009)

1 Exhibit

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2 Exhibit

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3 Exhibit

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4 Exhibit

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5 Exhibit

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April 27, 2009 PACER
54

ORDER denying 51 Motion for Protective Order. Signed by Magistrate Judge Gerald B. Cohn on 5/7/2009. (Cohn, Gerald) (Entered: 05/07/2009)

May 7, 2009 PACER
55

MOTION to Amend/Correct Proposed Order and Supporting Documents Submitted by Paramount Staffing, Inc.. (Attachments: # 1 Certificate of Consultation)(Prather, Paul) (Entered: 05/13/2009)

1 Certificate of Consultation

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May 13, 2009 PACER
56

NOTICE of Appearance by Sylvia R. Adams on behalf of all defendants (Adams, Sylvia) (Entered: 05/15/2009)

May 15, 2009 PACER
57

RESPONSE to Motion re 55 MOTION to Amend/Correct Proposed Order and Supporting Documents Submitted filed by Equal Employment Opportunity Commission. (Dills, Steven) (Entered: 05/26/2009)

May 26, 2009 PACER
58

SETTING LETTER: Telephonic Hearing re: 55 Defendant's Motion to Amend Scheduling Order set for 6/10/2009 08:45 AM in Courtroom 1 - Memphis before Chief Judge Jon Phipps McCalla. (jpw) (Entered: 06/01/2009)

June 1, 2009 PACER
59

ORDER REASSIGNING REFERRAL JUDGE pursuant to Administrative Order 2009-14. Case reassigned to Magistrate Judge Charmiane G. Claxton for all further proceedings. Magistrate Judge Gerald B. Cohn no longer assigned to case. Signed by Chief Judge Jon Phipps McCalla on 6/9/09. (jae) (Additional attachment(s) added on 6/9/2009: # 1 Order) (jae). (Entered: 06/09/2009)

June 9, 2009 PACER
60

Minute Entry for proceedings held before Chief Judge Jon Phipps McCalla: Telephonic Hearing re: 55 Defendant's Motion to Amend Scheduling Order held on 6/10/2009. Motion heard and granted. Jury Trial reset to 8/30/2010 at 9:30 AM. Pretrial Conference reset to 8/23/2010 at 9:00 AM. Pretrial Order due by 4:30 PM on 8/16/2010. New Scheduling Order to be entered. (Plaintiff: Deidre Smith, Steven Dills) (Defense: Paul Prather, Sylvia Adams, Brenda Rae Nelson) (Court Reporter: Brenda Parker) (jpw) (Entered: 06/10/2009)

June 10, 2009 PACER
61

SETTING LETTER: Jury Trial reset for 8/30/2010 09:30 AM in Courtroom 1 - Memphis before Chief Judge Jon Phipps McCalla. Pretrial Conference reset for 8/23/2010 09:00 AM in Courtroom 1 - Memphis before Chief Judge Jon Phipps McCalla. Proposed Pretrial Order due by 8/16/2010. (jpw) (Entered: 06/10/2009)

June 10, 2009 PACER
62

ORDER Following Status Conference and Granting 55 Motion to Amend/Correct. Signed by Chief Judge Jon Phipps McCalla on 6/10/09. (McCalla, Jon) (Entered: 06/10/2009)

June 10, 2009 PACER
63

Joint MOTION for Leave to Modify the Fed.R.Civ.P. 16(b) Scheduling Order to Set New Deadlines (proposed order submitted) by Equal Employment Opportunity Commission. (Attachments: # 1 Memorandum in Support of Motion for Leave to Modify the Scheduling Order)(Smith, Deidre) (Entered: 09/04/2009)

1 Memorandum in Support of Motion for Leave to Modify the Scheduling Order

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Sept. 4, 2009 PACER
64

ORDER GRANTING JOINT 63 MOTION TO MODIFY RULE 16(b) SCHEDULING ORDER. Signed by Chief Judge Jon Phipps McCalla on 09/04/09. (McCalla, Jon) (Entered: 09/04/2009)

Sept. 4, 2009 PACER
65

MOTION in Limine to Exclude the Expert Report and Trial Testimony of Dr. David Sharp by Paramount Staffing, Inc.. (Attachments: # 1 Memorandum Memorandum in Support, # 2 Exhibit Exhibit A, # 3 Exhibit Exhibit B, # 4 Exhibit Exhibit C, # 5 Exhibit Exhibit D, # 6 Exhibit Exhibit E, # 7 Exhibit Exhibit F, # 8 Exhibit Exhibit G, # 9 Exhibit Exhibit H, # 10 Exhibit Exhibit I, # 11 Exhibit Exhibit J, # 12 Exhibit Exhibit K, # 13 Exhibit Exhibit L, # 14 Exhibit Exhibit M, # 15 Exhibit Exhibit N, # 16 Exhibit Exhibit O, # 17 Exhibit Exhibit P, # 18 Exhibit Exhibit Q, # 19 Exhibit Exhibit R, # 20 Exhibit Exhibit S, # 21 Exhibit Exhibit T, # 22 Exhibit Exhibit U, # 23 Exhibit Exhibit V, # 24 Exhibit Exhibit W, # 25 Exhibit Exhibit X, # 26 Exhibit Exhibit Y, # 27 Exhibit Exhibit Z, # 28 Exhibit Exhibit AA, # 29 Exhibit Exhibit BB)(Prather, Paul) (Entered: 12/14/2009)

1 Memorandum Memorandum in Support

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2 Exhibit Exhibit A

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3 Exhibit Exhibit B

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4 Exhibit Exhibit C

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5 Exhibit Exhibit D

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6 Exhibit Exhibit E

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7 Exhibit Exhibit F

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8 Exhibit Exhibit G

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9 Exhibit Exhibit H

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10 Exhibit Exhibit I

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11 Exhibit Exhibit J

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12 Exhibit Exhibit K

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13 Exhibit Exhibit L

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14 Exhibit Exhibit M

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15 Exhibit Exhibit N

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16 Exhibit Exhibit O

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17 Exhibit Exhibit P

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18 Exhibit Exhibit Q

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19 Exhibit Exhibit R

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20 Exhibit Exhibit S

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21 Exhibit Exhibit T

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22 Exhibit Exhibit U

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23 Exhibit Exhibit V

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24 Exhibit Exhibit W

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25 Exhibit Exhibit X

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26 Exhibit Exhibit Y

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27 Exhibit Exhibit Z

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28 Exhibit Exhibit AA

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29 Exhibit Exhibit BB

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Dec. 14, 2009 PACER
66

MOTION to Extend Deadline to Respond to Defendant's Motion in Limine to Exclude the Expert Report and Trial Testimony of Dr. David Sharp (proposed order submitted) by Equal Employment Opportunity Commission. (Attachments: # 1 Memorandum in Support of Motion to Extend Deadline, # 2 Certificate of Consultation)(Dills, Steven) (Entered: 12/17/2009)

1 Memorandum in Support of Motion to Extend Deadline

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2 Certificate of Consultation

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Dec. 17, 2009 PACER
67

Joint MOTION for Leave to File Excess Pages (Proposed Order Submitted) by Equal Employment Opportunity Commission. (Attachments: # 1 Memorandum in Support of Joint Motion to Exceed the Page Limit)(Smith, Deidre) (Entered: 12/18/2009)

1 Memorandum in Support of Joint Motion to Exceed the Page Limit

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Dec. 18, 2009 PACER
68

ORDER GRANTING PLAINTIFF'S UNOPPOSED 66 MOTION TO MODIFY DEADLINE TO RESPOND TO DEFENDANT'S MOTION IN LIMINE TO EXCLUDE THE EXPERT REPORT AND TRIALTESTIMONY OF DR. DAVID SHARP. Signed by Chief Judge Jon Phipps McCalla on 12/18/09. (McCalla, Jon) (Entered: 12/18/2009)

Dec. 18, 2009 PACER
69

TEXT ONLY ORDER: GRANTING 67 Motion for Leave to File Excess Pages (***no images associated with this entry***). Signed by Chief Judge Jon Phipps McCalla on 12/18/09. (McCalla, Jon) (Entered: 12/18/2009)

Dec. 18, 2009 PACER
70

SETTING LETTER: Telephonic Hearing re: 65 Defendant's Motion in Limine to Exclude the Expert Report and Trial Testimony of Dr. David Sharp set for 2/25/2010 03:00 PM before Chief Judge Jon Phipps McCalla. (jpw) (Entered: 01/07/2010)

Jan. 7, 2010 PACER
71

MOTION Reschedule the Telephonic Hearing on Its Motion in Limine to Exclude the Expert Report and Trial Testimony of Dr. David Sharp re 70 Setting Letter Proposed Order Submitted by Paramount Staffing, Inc.. (Attachments: # 1 Certificate of Consultation)(Nelson, Brenda) (Entered: 01/20/2010)

1 Certificate of Consultation

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Jan. 20, 2010 PACER
72

MOTION for Extension of Time to File Response/Reply as to 65 MOTION in Limine to Exclude the Expert Report and Trial Testimony of Dr. David Sharp (proposed order submitted) by Equal Employment Opportunity Commission. (Attachments: # 1 Memorandum of Support, # 2 Certificate of Consultation)(Smith, Deidre) (Entered: 01/25/2010)

1 Memorandum of Support

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2 Certificate of Consultation

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Jan. 25, 2010 PACER
73

ORDER GRANTING DEFENDANT'S MOTION TO RESCHEDULE HEARING ON MOTION IN LIMINE TO EXCLUDE THE EXPERT REPORT AND TRIAL TESTIMONY OF DR. DAVID SHARP. Signed by Chief Judge Jon Phipps McCalla on 1/25/10. (McCalla, Jon) (Entered: 01/25/2010)

Jan. 25, 2010 PACER
74

TEXT-ONLY ORDER GRANTING 72 Motion for Extension of Time to File Response/Reply. Plaintiff has until January 29, 2010 to file a response. (**No Image Associated with this Order**). Signed by Chief Judge Jon Phipps McCalla on 1/25/10. (McCalla, Jon) (Entered: 01/25/2010)

Jan. 25, 2010 PACER
75

MOTION to Amend/Correct 74 Order on Motion for Extension of Time to File Response/Reply, proposed order submitted by Equal Employment Opportunity Commission. (Attachments: # 1 Certificate of Consultation)(Dills, Steven) (Entered: 01/27/2010)

1 Certificate of Consultation

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Jan. 27, 2010 PACER
76

TEXT-ONLY ORDER GRANTING 75 Motion to Amend/Correct Order on Motion for Extension of Time to File Response/Reply. Plaintiff has until February 5, 2010 to file a response. (**No Image Associated with this Order**). Signed by Chief Judge Jon Phipps McCalla on 1/28/10. (McCalla, Jon) (Entered: 01/28/2010)

Jan. 28, 2010 PACER
77

RESPONSE in Opposition re 65 MOTION in Limine to Exclude the Expert Report and Trial Testimony of Dr. David Sharp (Proposed Order submitted) filed by Equal Employment Opportunity Commission. (Attachments: # 1 Memorandum in Support of Response, # 2 Exhibit 1 - Defendants Response to Plaintiff's Req for Interrogatories, # 3 Exhibit 2 - Sharp Rebuttal Report, # 4 Exhibit 3 - Conrado depo excerpts, # 5 Exhibit 4 - Cardenas depo excerpts, # 6 Exhibit Detail by Purchase Order, # 7 Exhibit Reference Manual on Scientific Evidence, # 8 Exhibit 7 - Sharp Expert Report, # 9 Exhibit 8 - Sharp depo excerpts, # 10 Exhibit 9 - Baker depo excerpts, # 11 Exhibit 9a - Exhibit 6 to Baker depo, # 12 Exhibit 10 - Baldus and Cole article, # 13 Exhibit Paetzold and Willborn article, # 14 Exhibit 12 - Appendix H to Baker Report, # 15 Exhibit 13 - Appendix N to Baker Report, # 16 Exhibit 14 - Rush depo excerpts, # 17 Exhibit 15 - Abram depo excerpts, # 18 Exhibit 16 - Beason depo excerpts, # 19 Exhibit 17 - Brown depo excerpts, # 20 Exhibit 18 - Cummings depo excerpts, # 21 Exhibit 19 - A Davis depo excerpts, # 22 Exhibit 20 - L Davis depo excerpts, # 23 Exhibit 21 - Douglas depo excerpts, # 24 Exhibit 22 - Drinkwater depo excerpts, # 25 Exhibit 23 - Gardner depo excerpts, # 26 Exhibit 24 - Gilmore-Marshal depo excerpts, # 27 Exhibit 25 - Jennings depo excerpts, # 28 Exhibit 26 - Lee depo excerpts, # 29 Exhibit 27 - Lester depo excerpts, # 30 Exhibit 28 - G Mitchell depo excerpts, # 31 Exhibit 29 - J Mitchell depo excerpts, # 32 Exhibit 30 - Morrison depo excerpts, # 33 Exhibit 31 - Nelson depo excerpts, # 34 Exhibit 32 - Wooten depo excerpts)(Smith, Deidre) (Entered: 02/05/2010)

1 Memorandum in Support of Response

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2 Exhibit 1 - Defendants Response to Plaintiff's Req for Interrogatories

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3 Exhibit 2 - Sharp Rebuttal Report

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4 Exhibit 3 - Conrado depo excerpts

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5 Exhibit 4 - Cardenas depo excerpts

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6 Exhibit Detail by Purchase Order

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7 Exhibit Reference Manual on Scientific Evidence

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8 Exhibit 7 - Sharp Expert Report

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9 Exhibit 8 - Sharp depo excerpts

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10 Exhibit 9 - Baker depo excerpts

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11 Exhibit 9a - Exhibit 6 to Baker depo

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12 Exhibit 10 - Baldus and Cole article

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13 Exhibit Paetzold and Willborn article

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14 Exhibit 12 - Appendix H to Baker Report

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15 Exhibit 13 - Appendix N to Baker Report

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16 Exhibit 14 - Rush depo excerpts

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17 Exhibit 15 - Abram depo excerpts

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18 Exhibit 16 - Beason depo excerpts

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19 Exhibit 17 - Brown depo excerpts

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20 Exhibit 18 - Cummings depo excerpts

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21 Exhibit 19 - A Davis depo excerpts

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22 Exhibit 20 - L Davis depo excerpts

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23 Exhibit 21 - Douglas depo excerpts

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24 Exhibit 22 - Drinkwater depo excerpts

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25 Exhibit 23 - Gardner depo excerpts

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26 Exhibit 24 - Gilmore-Marshal depo excerpts

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27 Exhibit 25 - Jennings depo excerpts

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28 Exhibit 26 - Lee depo excerpts

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29 Exhibit 27 - Lester depo excerpts

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30 Exhibit 28 - G Mitchell depo excerpts

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31 Exhibit 29 - J Mitchell depo excerpts

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32 Exhibit 30 - Morrison depo excerpts

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33 Exhibit 31 - Nelson depo excerpts

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34 Exhibit 32 - Wooten depo excerpts

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Feb. 5, 2010 PACER
78

NOTICE by Equal Employment Opportunity Commission re 77 Response in Opposition to Motion,,,,,,, The attached exhibit was inadvertently omitted from the exhibits filed with Docket 77. Ex 33 - Winkleby and Rockhill article, relates to FN 23 of Plaintiff's Memo. (Smith, Deidre) (Entered: 02/09/2010)

Feb. 9, 2010 PACER
79

MOTION for Leave to File Reply to Plaintiffs' Response in Opposition to Defendant's Motion to Exclude the Expert Report and Trial Testimony of Dr. David Sharp (Proposed Order Submitted) by Paramount Staffing, Inc.. (Prather, Paul) (Entered: 02/18/2010)

Feb. 18, 2010 PACER
80

TEXT-ONLY ORDER GRANTING 79 Unopposed Motion for Leave to File a Reply. (**No Images Associated with this Order**). Signed by Chief Judge Jon Phipps McCalla on 2/17/10. (McCalla, Jon) (Entered: 02/18/2010)

Feb. 18, 2010 PACER
81

NOTICE of Appearance by Steven Hymowitz on behalf of Paramount Staffing, Inc. (Hymowitz, Steven) (Entered: 02/22/2010)

Feb. 22, 2010 PACER
82

REPLY to Response to Motion re 79 MOTION for Leave to File Reply to Plaintiffs' Response in Opposition to Defendant's Motion to Exclude the Expert Report and Trial Testimony of Dr. David Sharp (Proposed Order Submitted) filed by Paramount Staffing, 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, # 11 Exhibit K, # 12 Exhibit L)(Prather, Paul) (Entered: 02/22/2010)

1 Exhibit A

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2 Exhibit B

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3 Exhibit C

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4 Exhibit D

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5 Exhibit E

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6 Exhibit F

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7 Exhibit G

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8 Exhibit H

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9 Exhibit I

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10 Exhibit J

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11 Exhibit K

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12 Exhibit L

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Feb. 22, 2010 PACER
83

MOTION for Leave to File to File Sur-Reply in Support of its Response in Opposition to Defendant's Motion to Exclude the Expert Report and Trial Testimony of Dr. David Sharp (proposed order submitted) by Equal Employment Opportunity Commission. (Attachments: # 1 Memorandum in Support, # 2 Certificate of Consultation)(Smith, Deidre) (Entered: 02/23/2010)

1 Memorandum in Support

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2 Certificate of Consultation

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Feb. 23, 2010 PACER
84

TEXT-ONLY ORDER GRANTING 83 Motion for Leave to File Sur-Reply. Plaintiff must file its sur-reply by 9:00 a.m. on February 25, 2010. (**No Images Associated with this Order**). Signed by Chief Judge Jon Phipps McCalla on 2/23/10. (McCalla, Jon) (Entered: 02/23/2010)

Feb. 23, 2010 PACER
85

REPLY to Response to Motion re 65 MOTION in Limine to Exclude the Expert Report and Trial Testimony of Dr. David Sharp filed by Equal Employment Opportunity Commission. (Attachments: # 1 Memorandum in Support, # 2 Exhibit 1 - Depo excerpts of Shannon Hayes, # 3 Exhibit 2 - Depo excerpts of Mary Jacobs, # 4 Exhibit 3 - Depo excerpts of Anthony Jennings, # 5 Exhibit 4 - Depo excerpts of Wilma Jones, # 6 Exhibit 5 - Depo excerpts of Gladys Mitchell, # 7 Exhibit 6 - Depo excerpts of Tina Morrison, # 8 Exhibit 7 - Depo excerpts of Obbrel Nelson, # 9 Exhibit 8 - Depo excerpts of Angela Price, # 10 Exhibit 9 - Depo excerpts of Chester Reed, # 11 Exhibit 10 - Depo excerpts of Sherrita Smith, # 12 Exhibit 11 - Depo excerpts of James Taylor, # 13 Exhibit 12 - Depo excerpts of Leslie Wooten, # 14 Exhibit 13 - Depo excerpts of Deborah Bady, # 15 Exhibit 14 - Depo excerpts Alfredo Cardenas, # 16 Exhibit 15 - Depo excerpts of James Culp, # 17 Exhibit 16 - Depo excerpts of Jeromie Holmes, # 18 Exhibit 17 - Depo excerpts of Yvonne Lester, # 19 Exhibit 18 - Depo excerpts of Yariela Conrado, # 20 Exhibit 19 - Mary Dunn Baker depo Exhit 5, # 21 Exhibit 20 - Depo excerpts of Mary Dunn Baker, # 22 Exhibit 21 - Sharp Reply Report, # 23 Exhibit 22 -Depo excerpts of Lawrence Schmitt)(Smith, Deidre) (Entered: 02/25/2010)

1 Memorandum in Support

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2 Exhibit 1 - Depo excerpts of Shannon Hayes

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3 Exhibit 2 - Depo excerpts of Mary Jacobs

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4 Exhibit 3 - Depo excerpts of Anthony Jennings

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5 Exhibit 4 - Depo excerpts of Wilma Jones

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6 Exhibit 5 - Depo excerpts of Gladys Mitchell

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7 Exhibit 6 - Depo excerpts of Tina Morrison

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8 Exhibit 7 - Depo excerpts of Obbrel Nelson

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9 Exhibit 8 - Depo excerpts of Angela Price

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10 Exhibit 9 - Depo excerpts of Chester Reed

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11 Exhibit 10 - Depo excerpts of Sherrita Smith

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12 Exhibit 11 - Depo excerpts of James Taylor

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13 Exhibit 12 - Depo excerpts of Leslie Wooten

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14 Exhibit 13 - Depo excerpts of Deborah Bady

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15 Exhibit 14 - Depo excerpts Alfredo Cardenas

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16 Exhibit 15 - Depo excerpts of James Culp

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17 Exhibit 16 - Depo excerpts of Jeromie Holmes

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18 Exhibit 17 - Depo excerpts of Yvonne Lester

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19 Exhibit 18 - Depo excerpts of Yariela Conrado

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20 Exhibit 19 - Mary Dunn Baker depo Exhit 5

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21 Exhibit 20 - Depo excerpts of Mary Dunn Baker

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22 Exhibit 21 - Sharp Reply Report

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23 Exhibit 22 -Depo excerpts of Lawrence Schmitt

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Feb. 25, 2010 PACER
86

Minute Entry for proceedings held before Chief Judge Jon Phipps McCalla: Hearing re: 65 Defendant's Motion in Limine to Exclude the Expert Report and Trial Testimony of Dr. David Sharp held on 2/25/2010. Arguments heard. Sworn witness for the Plaintiff: Dr. David Sharp. Defense counsel to consult and decide if they wish to call any witnesses. Parties to contact the case manager if they wish to put on additional proof/tesimony. (for Plaintiff: Deidre Smith) (for Defense: Paul Prather, Brenda Nelson, Steven Hymowitz) (Court Reporter: Brenda Parker) (jpw) (Entered: 02/26/2010)

Feb. 25, 2010 PACER
87

RESPONSE to Motion re 83 MOTION for Leave to File to File Sur-Reply in Support of its Response in Opposition to Defendant's Motion to Exclude the Expert Report and Trial Testimony of Dr. David Sharp (proposed order submitted) MOTION for Leave to File to File Sur-Reply in Support of its Response in Opposition to Defendant's Motion to Exclude the Expert Report and Trial Testimony of Dr. David Sharp (proposed order submitted) filed by Paramount Staffing, Inc.. (Attachments: # 1 Exhibit, # 2 Exhibit)(Prather, Paul) (Entered: 02/26/2010)

1 Exhibit

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2 Exhibit

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Feb. 26, 2010 PACER
88

MOTION for Leave to File a Supplemental Brief Following the February 25, 2010 Hearing (proposed order submitted) by Equal Employment Opportunity Commission. (Attachments: # 1 Memorandum in Support, # 2 Certificate of Consultation)(Smith, Deidre) (Entered: 03/03/2010)

1 Memorandum in Support

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2 Certificate of Consultation

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March 3, 2010 PACER
89

TEXT-ONLY ORDER GRANTING 88 Unopposed Motion for Leave to File a Supplemental Brief. (***No Images Associated with this Order***). Signed by Chief Judge Jon Phipps McCalla on 3/3/10. (McCalla, Jon) (Entered: 03/03/2010)

March 3, 2010 PACER
90

NOTICE by Equal Employment Opportunity Commission re 65 MOTION in Limine to Exclude the Expert Report and Trial Testimony of Dr. David Sharp (Supplemental Brief Following the February 25, 2010 Hearing) (Attachments: # 1 Exhibit 1 Census Data, # 2 Exhibit 2 Depo excerpts of Alfredo Cardenas, # 3 Exhibit 3 Depo excerpts of Dexter Rush, # 4 Exhibit 4 Depo excerpts of Bobett Collins, # 5 Exhibit 5 Depo excerpts of Michelle Douglas, # 6 Exhibit Depo excerpts of Shannon Hayes, # 7 Exhibit 7 Depo excerpts of Kevin German)(Smith, Deidre) (Entered: 03/05/2010)

1 Exhibit 1 Census Data

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2 Exhibit 2 Depo excerpts of Alfredo Cardenas

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3 Exhibit 3 Depo excerpts of Dexter Rush

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4 Exhibit 4 Depo excerpts of Bobett Collins

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5 Exhibit 5 Depo excerpts of Michelle Douglas

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6 Exhibit Depo excerpts of Shannon Hayes

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7 Exhibit 7 Depo excerpts of Kevin German

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March 5, 2010 PACER
91

MOTION to Strike Supplemental Rule 26 disclosure, proposed order submitted by Equal Employment Opportunity Commission. (Attachments: # 1 Memorandum, # 2 Certificate of Consultation, # 3 Exhibit Def. Disclosure of March 15, 2010, # 4 Exhibit Letter dated March 16, 2010)(Dills, Steven) Modified on 4/19/2010 (jml).Exhibit Def. Disclosure of March 15, 2010, sealed from further viewing(consist of personal identifiers per Nancy from EEOC). (Entered: 03/19/2010)

1 Memorandum

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2 Certificate of Consultation

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4 Exhibit Letter dated March 16, 2010

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March 19, 2010 PACER
92

ORDER OF REFERENCE FOR DETERMINATION: 91 MOTION to Strike Supplemental Rule 26 disclosure, proposed order submitted filed by Equal Employment Opportunity Commission. Signed by Chief Judge Jon Phipps McCalla on 3/23/10. (McCalla, Jon) (Entered: 03/23/2010)

March 23, 2010 PACER
93

MOTION for Extension of Time to Complete Discovery Motion and Memorandum by Paramount Staffing, Inc.. (Attachments: # 1 Certificate of Consultation)(Prather, Paul) (Entered: 03/25/2010)

1 Certificate of Consultation

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March 25, 2010 PACER
94

TEXT-ONLY ORDER GRANTING 93 Motion for Extension of Time to Complete Discovery. The discovery deadline is extended to May 31, 2010. (**No Image Associated with this Order**). Signed by Chief Judge Jon Phipps McCalla on 3/26/10. (McCalla, Jon) (Entered: 03/26/2010)

March 26, 2010 PACER
96

NOTICE OF SETTING: A MOTION HEARING has been set for MONDAY, 4/19/2010 at 02:00 PM in Courtroom M3 - Memphis before Magistrate Judge Charmiane G. Claxton. (bvh) (Entered: 04/07/2010)

April 7, 2010 PACER
97

Minute Entry for proceedings held before Magistrate Judge Charmiane G. Claxton: Motion Hearing held on 4/19/2010 re 91 MOTION to Strike Supplemental Rule 26 disclosure filed by Equal Employment Opportunity Commission. Counsel for the parties present. Plaintiff states that defendant has produced over 700 individuals in their supplemental disclosures with no identifying information provided. Plaintiff attempted to research the individuals names and was not able to locate several. Plaintiff has requested from defendant the names of individuals that can be deposed and has not received a response. Plaintiff believes there is not enough time to locate and have depositions for the individuals within the remaining discovery period. Defendant agrues that the plaintiff disclosed over 1200 individuals. Defendant states that the plaintiff is aware of who the individuals are and what they will testify about. Defendant is having the same problem as the plaintiff with regards to locating and contacting the individuals due to disconnected phone numbers, etc. Defendant estimates that they will be able to produce about 20 individuals for deposition. Defendant expects to have the individuals narrowed down from the original 700 by the end of the week. Plaintiff agrues that they should be provided with an estimate of the number of individuals being produced as soon as possible. The Court orders that the defendant may not produce more than 50 individuals for deposition and that the defendant is to supplement their disclosures by Friday, April 23, 2010. Plaintiff is to draft an order, circulate to defense counsel, and submit it to the Court for final approval and entry within one week. The Court also address the issue of some individual personal information being contained in exhibits to the Motion and Response. The parties are directed to submit redacted copies of their respective exhibits. Parties are to contact the Court's ECF Help Desk is assistance is needed in filing the redacted copies.(Plaintiffs Counsel: D. Smith & S. Dills. Defense Counsel: B. Nelson.) (Tape #FTR) (cas) (Entered: 04/20/2010)

April 19, 2010 PACER
98

ORAL ORDER. By Oral Order of the Court Docket Entry # 91 Motion and Docket Entry # 95 Response have been SEALED from public view due to personal information being contained in the documents. Signed by Magistrate Judge Charmiane G. Claxton on 4/19/2010. *TEXT ENTRY ONLY - THERE IS NO IMAGE ASSOCIATED WITH THIS ORDER*(Claxton, Charmiane) (Entered: 04/20/2010)

April 19, 2010 PACER
99

REDACTION Exhibit C by Paramount Staffing, Inc.. (Nelson, Brenda) (Entered: 04/20/2010)

April 20, 2010 PACER
100

REDACTION to 91 MOTION to Strike Supplemental Rule 26 disclosure, proposed order submitted (Redaction to Exhibit 3 of 91 ) by Equal Employment Opportunity Commission. (Dills, Steven) (Entered: 04/20/2010)

April 20, 2010 PACER
101

MOTION to Extend Deadline Proposed Order Submitted by Paramount Staffing, Inc.. (Attachments: # 1 Certificate of Consultation)(Nelson, Brenda) (Entered: 04/23/2010)

1 Certificate of Consultation

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April 23, 2010 PACER

State / Territory: Tennessee

Case Type(s):

Equal Employment

Special Collection(s):

EEOC Study — in sample

Key Dates

Filing Date: Sept. 22, 2006

Closing Date: Aug. 19, 2010

Case Ongoing: No

Plaintiffs

Plaintiff Description:

Equal Employment Opportunity Commission, on behalf of one or more workers.

Plaintiff Type(s):

EEOC Plaintiff

Attorney Organizations:

EEOC

Public Interest Lawyer: Yes

Filed Pro Se: No

Class Action Sought: No

Class Action Outcome: Not sought

Defendants

Paramount Staffing, Inc. (Memphis), Private Entity/Person

Case Details

Causes of Action:

Title VII (including PDA), 42 U.S.C. § 2000e

Availably Documents:

Trial Court Docket

Complaint (any)

Monetary Relief

Injunctive (or Injunctive-like) Relief

Outcome

Prevailing Party: None Yet / None

Nature of Relief:

Injunction / Injunctive-like Settlement

Damages

Source of Relief:

Settlement

Form of Settlement:

Court Approved Settlement or Consent Decree

Amount Defendant Pays: 585,000

Order Duration: 2010 - 2012

Content of Injunction:

Develop anti-discrimination policy

Follow recruitment, hiring, or promotion protocols

Reporting

Issues

General:

Disparate Treatment

Retaliation

Discrimination-area:

Discharge / Constructive Discharge / Layoff

Hiring

Discrimination-basis:

National origin discrimination

Race discrimination

EEOC-centric:

Direct Suit on Merits