Case: EEOC v. Gold River Operating Corporation

EEOC v. Gold River Operating Corporation, et al

EEOC v. Gold River Operating Corporation, et al

EEOC v. Gold River Operating Corporation, et al

EEOC v. Gold River Operating Corporation, etal

EEOC v. Gold River Operating Corporation, et al

EEOC v. Gold River Operating Corporation, etal

EEOC v. Gold River Operating Corporation, etal

EEOV v. Gold River Operating Corp.

Carly Knight, Frank Dobbin, Alexandra Kalev

SUMMONS ISSUED to P (1) (Entered: 10/15/2004)

COMPLAINT w/JD obo P (nss) (Entered: 10/15/2004)

COMPLAINT w/JD amended obo P (nss) (Entered: 10/15/2004)

WAIVER OF SERVICE EXECUTED by D/Gold River Operating Corp obo P (m) (Entered: 12/03/2004)

CERTIFICATE OF INTERESTED PARTIES obo D/Columbia Sussex Corporation (m) (cpy RCJ/LRL) (Entered: 12/06/2004)

ANSWER TO COMPLAINT obo Columbia Sussex Corporation (m) (Entered: 12/06/2004)

ANSWER TO COMPLAINT obo D/Gold River Operating Corporation (m) (Entered: 12/06/2004)

CERTIFICATE OF INTERESTED PARTIES obo D/Gold River Operating Corporation (m) (cpy RCJ/LRL) (Entered: 12/08/2004)

MISCELLANEOUS DOCUMENT vp &designation of out/state cnsl Herbert C. Ehrhardt &Linda Claxton for D. Sub to RCJ. (Entered: 01/13/2005)

MISCELLANEOUS DOCUMENT vp &Designation of cnsl for out/state cnsl Leslie E. Wallis. Sub to RCJ. (Entered: 01/13/2005)

VERIFIED PETITION FOR PERMISSION TO PRACTICE PRO HAC VICE of Leslie E. Wallis (ptnr) as out/state cnsl for D/Columbia Sussex Corp. cpys dist. (Entered: 01/24/2005)

DESIGNATION OF LOCAL COUNSEL obo Mary Kristina Pickering, local cnsl for D/Columbia Sussex Corp (Leslie E. Wallis). cpys dist. (Entered: 01/24/2005)

VERIFIED PETITION FOR PERMISSION TO PRACTICE PRO HAC VICE of Linda Claxton (ptnr) as out/state cnsl for D/Columbia Sussex Corp. cpys dist. (Entered: 01/24/2005)

DESIGNATION OF LOCAL COUNSEL obo Mary Kristina Pickering, local cnsl for D/Columbia Sussex Corp (Linda Claxton). cpys dist. (Entered: 01/24/2005)

DESIGNATION OF LOCAL COUNSEL obo Mary Kristina Pickering, local cnsl for D/Columbia Sussex Corp (Herbert C Erhardt). cpys dist. (Entered: 01/24/2005)

MISCELLANEOUS DOCUMENT stip disc plan/sked. Sub to LRL (Entered: 01/21/2005)

ORDER ON STIPULATION ORD DISC due 1/13/06; MTNS due 3/20/06; JTPTO due 5/15/06; (see doc). cpys dist. (Entered: 01/24/2005)

MAIL RETURNED re #14 mailed to Ds cnsl returned marked "Attempted not Known", snt to new address. (Entered: 02/04/2005)

MISCELLANEOUS DOCUMENT consent to proceed bfr US Magistrate Judge (LRL). Sub to LRL (Entered: 02/14/2005)

ORDER ORD consent to proceed bfr a US Magistrate is GRANTED, (see doc). cpys dist. (Entered: 02/24/2005)

MAIL RETURNED re #8 − #13 mailed to Ds cnsl returned marked "Attempted not Known", snt to new address. (Entered: 02/25/2005)

NOTICE OF APPEARANCE of govt atty Connie Liem as cnsl obo P (m) (Entered: 05/17/2005)

MISCELLANEOUS DOCUMENT Ntc of errata to paragraph 7 of 1st amndd complaint. (nss) (Entered: 07/29/2005)

MISCELLANEOUS DOCUMENT stip to ext time to resp to disc − LRL (Entered: 08/01/2005)

ORDER ON STIPULATION (1st req) To ext time to resp to disc requests ext to 8/29/05. (cps dist) (Entered: 08/05/2005)

SUBPOENA RETURNED EXECUTED (17) subpoenas as to Birgit K. Baker, Director Nevada Dept of Employment on 9/30/05 obo D (Entered: 10/19/2005)

SUBPOENA RETURNED EXECUTED as to Custodian of Records; Edgewater Hotel &Casino on 10/7/05 obo D (Entered: 10/19/2005)

SUBPOENA RETURNED EXECUTED as to Custodian of Records; Flamingo Hilton on 10/7/05 obo D (Entered: 10/19/2005)

SUBPOENA RETURNED EXECUTED as to Custodian of Records; Riverside Casino on 10/7/05 obo D (Entered: 10/19/2005)

SUBPOENA RETURNED EXECUTED as to Custodian of Records; Avi Hotel &Casino on 10/7/05 obo D (Entered: 10/19/2005)

SUBPOENA RETURNED EXECUTED (2) as to Custodian of Records; Harrah's on 10/7/05 obo D (Entered: 10/19/2005)

MOTION TO QUASH Ds improperly served subpoenas obo P (m) (DISPO: declaratn #28; order #30; oppo #32; (Entered: 10/24/2005)

DECLARATION of Dana Johnson in supt of mtn to quash (#27) obo P (m) (Entered: 10/24/2005)

MOTION TO QUASH late served subpoenas obo P (m) (FLD SEP) (DISPO: order #30; oppo #32; (Entered: 10/24/2005)

MISCELLANEOUS DOCUMENT stip to ext time to resp to disc. Sub to LRL (Entered: 11/01/2005)

ORDER ON STIPULATION ORD entension of time to 11/4/05 to file oppo, and 11 dys for Ps to file reply to mtns to quash (#27/#29) is GRANTED (Entered: 11/03/2005)

RESPONSE IN OPPOSITION TO MOTION to mtn to quash (#27) and mtn to quash (#29) obo Ds (m) (Entered: 11/04/2005)

RESPONSE to 29 Motion to Quash; filed by Defendant Casino Columbia Sussex Corporation. (MAJ, ) (Entered: 11/10/2005)

JOINDER to 32 Opposition to 29 Motion to Quash, 27 Motion to Quash; filed by Defendant Gold River Operating Corporation. (MJZ ) (Entered: 12/02/2005)

REPLY to Response to 27 Motion to Quash; filed by Plaintiff Equal Employment Opportunity Commission. (GEW) (Entered: 11/23/2005)

DECLARATION of Herbert C. Ehrhardt in support of 32 Response in Opposition to Motion, re 27 Motion to Quash, 29 Motion to Quash; by Defendant Casino Columbia Sussex Corporation. (MJZ ) (Entered: 12/02/2005)

DECLARATION of Victor Viramontes in support of 29 Motion to Quash, 27 Motion to Quash; by Plaintiff Equal Employment Opportunity Commission. (MJZ ) (Entered: 12/02/2005)

Submission of PROPOSED ORDER filed by Plaintiff Equal Employment Opportunity Commission. (AXM, ) (Entered: 12/21/2005)

MOTION for Extension of Time for discovery (part 1 of 2) by Plaintiff Equal Employment Opportunity Commission. (AXM, ) (Entered: 12/21/2005)

MOTION For leave to take additional depositions (part 2 of 2) by Plaintiff Equal Employment Opportunity Commission. Responses due by 1/8/2006. (AXM) (Entered: 12/21/2005)

DECLARATION of Dana Johnsons re 40 MOTION For leave to take additional depositions; filed by Plaintiff Equal Employment Opportunity Commission. (AXM, ) (Entered: 12/21/2005)

DECLARATION of Victor Viramontes re 40 MOTION For leave to take additional depositions; filed by Plaintiff Equal Employment Opportunity Commission. (AXM ) (Entered: 12/21/2005)

STIPULATION for time to take depositions, by Defendant Casino Columbia Sussex Corporation. (AXM, ) (Entered: 12/23/2005)

RESPONSE to 40 MOTION For leave to take additional depositions; filed by Defendant Gold River Operating Corporation. (MJZ ) (Entered: 12/28/2005)

ORDER ON STIPULATION re 43 Stipulation for extending depositions. Signed by Judge Lawrence R. Leavitt on 1/6/06. (AXM, ) (Entered: 01/10/2006)

ORDER ON STIPULATION re 43 Stipulation to Take Depositions. Signed by Judge Lawrence R. Leavitt on 1/5/06. (MJZ) (Entered: 01/12/2006)

ORDER granting 39 Motion for Extension of Time. Discovery is extended 90 days. Discovery due by 4/11/2006. Signed by Judge Lawrence R. Leavitt on 01/11/06. (MBS, ) (Entered: 01/11/2006)

ORDER granting 40 Motion for Leave to Take Additional Depostions, to the extent the plaintiffs may now take 25 total depositions. Signed by Judge Lawrence R. Leavitt on 01/11/06. (MBS, ) (Entered: 01/11/2006)

ORDER Setting Hearing on 27 Motion to Quash, 29 Motion to Quash: Motion Hearing set for 2/27/2006 10:00 AM before Magistrate Judge Lawrence R. Leavitt. Signed by Judge Lawrence R. Leavitt on 2/6/06. (AXM, ) (Entered: 02/06/2006)

MINUTES OF PROCEEDINGS − Motion Hearing held on 2/27/2006 before Judge Lawrence R. Leavitt. Crtrm Administrator: K. Goetsch ; Pla Counsel: Victor Viramontes ; Def Counsel: Linda Claxton for Casino Columbia Sussex Corp; and Norman Kirshman for Gold River ; Court Reporter/FTR #: 10:09:37−12:05:13 ; Time of Hearing: 10:00am . RE: 29 Motion to Quash filed by Equal Employment Opportunity Commission,, 27 Motion to Quash filed by Equal Employment Opportunity Commission, The Court hears arguments of counsel. The Court directs counsel to submit their respective proposed orders for the Court's consideration if, following today's hearing, counsel are unable to come to a resolution of this matter. Additionally, discussion is held with regard to a concern raised by Mr. Kirshman relating to some allegedly altered documents. The Court directs the EEOC to investigate the matter and to report its findings to the Court at a status conference. (SEE ATTACHED MINUTES) Telephonic Status Conference set for 3/9/2006 11:00 AM in LV Courtroom 3C before Magistrate Judge Lawrence R. Leavitt. (KXG, ) (Entered: 03/06/2006)

Set/Reset Hearings: Telephonic Status Hearing set for 3/9/2006 11:00 AM in LV Courtroom 3C before Magistrate Judge Lawrence R. Leavitt. (KXG, ) (Entered: 03/01/2006)

NOTICE of Appearance by attorney Rex Garner on behalf of Defendants Casino Columbia Sussex Corporation, Gold River Operating Corporation. (Garner, Rex) (Entered: 03/01/2006)

MINUTES OF PROCEEDINGS − Status Conference held on 3/9/2006 before Judge Lawrence R. Leavitt. Crtrm Administrator: K. Goetsch ; Pla Counsel: Dana Johnson and Victor Viramontes ; Def Counsel: Linda Claxton for Casino Columbia Sussex Corporation; and Norman Kirshman for Gold River Operating Corporation ; Court Reporter/FTR #: 11:01:22−11:53:00 ; Time of Hearing: 11:00am . Court makes inquiry and hears representations of counsel. Deadlines are extended as follows (SEE ATTACHED MINUTES FOR DETAILS): Discovery due by 7/14/2006. Motions due by 8/14/2006. Proposed Joint Pretrial Order due by 9/13/2006. Submission of Proposed Orders re Motions to Quash (nos. 27 and 29) due by 3/17/2006. (KXG, ) (Entered: 03/09/2006)

ERROR: Wrong image attached; CORRECTION: Counsel advised to re−file Amended Complaint with correct image. (MJZ) (Entered: 03/13/2006)

AMENDED COMPLAINT with Jury Demand against all defendants, filed by Equal Employment Opportunity Commission.(Park, Anna) (Entered: 03/13/2006)

Submission of PROPOSED ORDER filed by Defendant Casino Columbia Sussex Corporation. ORDER GRANTING IN PART PLAINTIFF EEOC?S MOTION TO QUASH DEFENDANTS? SUBPOENAS AND ORDER MODIFYING REMAINING SUBPOENAS, MOTION AT DOCKET 27 (Claxton, Linda) (Entered: 03/17/2006)

Submission of PROPOSED ORDER filed by Defendant Casino Columbia Sussex Corporation. ORDER GRANTING IN PART PLAINTIFF EEOC?S MOTION TO QUASH DEFENDANTS SUBPOENAS AND ORDER MODIFYING REMAINING SUBPOENAS, MOTION AT DOCKET 29 (Claxton, Linda) (Entered: 03/17/2006)

MOTION to Intervene, filed by Intervenor Toni Ann PurtdyResponses due by 4/9/2006. (RFJ) (Entered: 03/23/2006)

ORDER granting 27 Motion to Quash. Signed by Judge Lawrence R. Leavitt on 3/23/06. (AXM, ) (Entered: 03/24/2006)

ORDER granting 29 Motion to Quash. Signed by Judge Lawrence R. Leavitt on 3/23/06. (AXM, ) (Entered: 03/24/2006)

EXHIBIT(s) re: phone records filed by Defendant Toni Ann Purdy. (RFJ) (Entered: 03/30/2006)

Mail Returned as Undeliverable re 52 Status Conference, addressed to Linda Claxton. (re−mld to new suite #) (MAJ) (Entered: 04/05/2006)

ORDER no action take at this time: re 57 MOTION to Intervene filed by Toni Ann Purdy; The putative intervenor has until May 17, 2006 to correct this deficiency. Signed by Judge Lawrence R. Leavitt on 4/20/06. (AXM, ) (Entered: 04/21/2006)

EMERGENCY MOTION to Quash subpoena by Defendant Toni Ann Purdy. (AXM, ) (Entered: 05/12/2006)

RESPONSE to 63 MOTION to Quash; filed by Defendant Gold River Operating Corporation. (Kirshman, Norman) (Entered: 05/15/2006)

ORDER denying 63 Motion to Quash. Signed by Judge Lawrence R. Leavitt on 5/15/06. (AXM) (Entered: 05/16/2006)

LETTER from Toni A. Purdy. (AAB) (Entered: 05/22/2006)

ORDER denying as moot 66 Motion for Extension of Time. Signed by Judge Lawrence R. Leavitt on 05/19/06. (MBS, ) (Entered: 05/19/2006)

ORDER DENYING without prejudice 57 Motion to Intervene. Signed by Judge Lawrence R. Leavitt on 5/22/06. (RFJ) (Entered: 05/24/2006)

AFFIDAVIT of Toni Purdy to motion 57 to intervene. (AXM) (Entered: 05/25/2006)

LETTER from Toni Purdy. (AXM) (Entered: 05/31/2006)

MOTION to Reconsider Magistrate Judge Order re 69 Order on Motion to Intervene by Defendant Toni Ann Purdy. Responses due by 6/18/2006. (AXM) (Entered: 05/31/2006)

ORDER establishing deadlines re 57 MOTION to Intervene filed by Toni Ann Purdy. Responses due by 6/22/2006. Replies due by 7/3/2006. Signed by Judge Lawrence R. Leavitt on 6/8/06. (RFJ) (Entered: 06/09/2006)

NON−OPPOSITION to 57 MOTION to Intervene; filed by Plaintiff Equal Employment Opportunity Commission. (Johnson, Dana) (Entered: 06/09/2006)

CERTIFICATE OF SERVICE by Intervenor Toni Ann Purdy as to Motion to reverse decision and motion for intervention. (AXM) (Entered: 06/16/2006)

NOTICE by Defendant Casino Columbia Sussex Corporation Notice of Correction of Firm Address (Claxton, Linda) (Entered: 06/26/2006)

REPLY to Response to 72 MOTION to Reconsider Magistrate Judge Order re 69 Order on Motion to Intervene; filed by Intervenor Toni Ann Purdy. (AXM) (Entered: 06/30/2006)

STIPULATION REGARDING THE CONTINUATION OF THE DEPOSITION OF JEANNE PATSKAN by Plaintiff Equal Employment Opportunity Commission. (Johnson, Dana) (Entered: 07/11/2006)

ORDER ON STIPULATION re 78 Stipulation to continue deposition of Jeanne Patskan. Signed by Judge Lawrence R. Leavitt on 7/18/06. (AXM) (Entered: 07/19/2006)

ORDER granting 72 Motion to Reverse Decision. Signed by Judge Lawrence R. Leavitt on 8/7/06. (MJZ) Docket Text Modified on 8/18/2006 (MJZ). (Entered: 08/10/2006)

MOTION for Partial Summary Judgment by Plaintiff Equal Employment Opportunity Commission. Responses due by 9/1/2006. (Johnson, Dana) (Entered: 08/14/2006)

DECLARATION of Barbara Bowers−Hughes in Support of Motion for Partial Summary Judgment by Plaintiff Equal Employment Opportunity Commission. (Johnson, Dana) (Entered: 08/14/2006)

DECLARATION of Dana C. Johnson in Support of Motion for Partial Summary Judgment by Plaintiff Equal Employment Opportunity Commission. (Attachments: # 1 Index Index of Exhibits to Declaration of Dana C. Johnson in Support of Motion for Partial Summary Judgment# 2 Exhibit Exhibits 1 to 3 − Part 1# 3 Exhibit Johnson Exhibits 1−3 Part 2# 4 Exhibit Johnson Exhibits 1−3, Part 3# 5 Exhibit Johnson Exhibits 4 − 12)(Johnson, Dana) (Entered: 08/14/2006)

MOTION to Dismiss OR IN THE ALTERNATIVE:REMAND TO EEOC FOR RECONSIDERATION OF DETERMINATION; COMPEL FURTHER ANSWERS TO QUESTIONS POSED DURING DEPOSITION, PURSUANT TO FED.R.CIV.P.37; AND SANCTIONS by Defendant Gold River Operating Corporation. Responses due by 9/2/2006. (Attachments: # 1 Exhibit Exhibits# 2 Exhibit)(Kirshman, Norman) (Entered: 08/15/2006)

RESPONSE to 85 MOTION to Dismiss OR IN THE ALTERNATIVE:REMAND TO EEOC FOR RECONSIDERATION OF DETERMINATION; COMPEL FURTHER ANSWERS TO QUESTIONS POSED DURING DEPOSITION, PURSUANT TO FED.R.CIV.P.37; AND SANCTIONS ; filed by Plaintiff Equal Employment Opportunity Commission. Replies due by 9/12/2006. (Johnson, Dana) (Entered: 08/29/2006)

DECLARATION of Dana C. Johnson re 85 MOTION to Dismiss OR IN THE ALTERNATIVE:REMAND TO EEOC FOR RECONSIDERATION OF DETERMINATION; COMPEL FURTHER ANSWERS TO QUESTIONS POSED DURING DEPOSITION, PURSUANT TO FED.R.CIV.P.37; AND SANCTIONS ; filed by Plaintiff Equal Employment Opportunity Commission. (Attachments: # 1 Exhibit)(Johnson, Dana) (Entered: 08/29/2006)

DECLARATION of EEOC Chairperson Cari M. Dominguez re 85 MOTION to Dismiss OR IN THE ALTERNATIVE:REMAND TO EEOC FOR RECONSIDERATION OF DETERMINATION; COMPEL FURTHER ANSWERS TO QUESTIONS POSED DURING DEPOSITION, PURSUANT TO FED.R.CIV.P.37; AND SANCTIONS ; filed by Plaintiff Equal Employment Opportunity Commission. (Johnson, Dana) (Entered: 08/29/2006)

NOTICE by Plaintiff Equal Employment Opportunity Commission re 85 MOTION to Dismiss OR IN THE ALTERNATIVE:REMAND TO EEOC FOR RECONSIDERATION OF DETERMINATION; COMPEL FURTHER ANSWERS TO QUESTIONS POSED DURING DEPOSITION, PURSUANT TO FED.R.CIV.P.37; AND SANCTIONS . Plaintiff EEOC's Lodgment of Additional Authorities In Support of its Opposition to Defendants' Motion to Dismiss (Attachments: # 1 Supplement Lodgment of Additional Authorities)(Johnson, Dana) (Entered: 08/29/2006)

RESPONSE to 81 MOTION for Partial Summary Judgment; filed by Defendant Casino Columbia Sussex Corporation. and Defendant Gold River Operating Corporation Replies due by 9/15/2006. (Claxton, Linda) (Entered: 09/01/2006)

DECLARATION of Lynn A. Vlahos re 90 Response to Motion for Partial Summary Judgment; by Defendant Casino Columbia Sussex Corporation. (Attachments: # 1 Exhibit A part 1# 2 Exhibit A part 2# 3 Exhibit A part 3# 4 Exhibit B# 5 Exhibit C)(Claxton, Linda) (Entered: 09/01/2006)

DECLARATION of Linda Claxton re 90 Response to Motion for Partial Summary Judgment; by Defendant Casino Columbia Sussex Corporation. (Attachments: # 1 # 2 # 3 # 4 # 5 # 6 # 7 # 8 # 9 # 10 # 11 # 12)(Claxton, Linda) (Entered: 09/01/2006)

REPLY to Response to 81 MOTION for Partial Summary Judgment; filed by Plaintiff Equal Employment Opportunity Commission. Reply in Support of EEOC's Motion for Partial Summary Judgment (Johnson, Dana) (Entered: 09/11/2006)

DECLARATION of Dana C. Johnson re 81 MOTION for Partial Summary Judgment; filed by Plaintiff Equal Employment Opportunity Commission. Declaration of Dana C. Johnson in Support of Plaintiff EEOC's Reply Brief in Connection with Motion for Partial Summary Judgment (Attachments: # 1 Index Index of Exhibits# 2 Exhibit Exhibit 1 Part 1# 3 Exhibit Exhibit 1 Part 2# 4 Exhibit Exhibit 1 Part 3# 5 Exhibit Exhibit 2 Part 1# 6 Exhibit Exhibit 2 Part 2# 7 Exhibit Exhibits 3 to 5)(Johnson, Dana) (Entered: 09/11/2006)

NOTICE of Change of Address by Intervenor Toni Ann Purdy. (AXM) (Entered: 09/20/2006)

NOTICE of Change of Address by Intervenor Toni Ann Purdy. Address previously updated. (MMM) (Entered: 11/20/2006)