Case: EEOC v. FOOT LOCKER SPECIALTY INC (f/k/a VENATOR GROUP SPECIALTY INC f/k/a F W WOOLWORTH CO INC)

Equal Employment v. Foot Locker Specialt, et al

EEOC v. Venator Group Specialty Inc

EEOC v. Foot Locker Specialty Inc

EEOC v. Foot Locker Specialty Inc

No Court

Carly Knight, Frank Dobbin, Alexandra Kalev

COMPLAINT filed; Summons issued and Notice pursuant to 28 U.S.C. 636(c); FILING FEE $ USA (jp) (Entered: 07/08/1999)

Magistrate Judge Kevin N. Fox is so Designated. (jp) (Entered: 07/08/1999)

Magistrate Judge Kevin N. Fox is so Designated. (jp)

INITIAL PRETRIAL CONFERNCE NOTICE; counsel are directed to appear in courtroom 14C at 500 Pearl Street on 9/27/99 at 4:15 p.m., for a pretrial conference with the Court for the purpose of discussing settlement, exploring contemplated motions, stipulating facts, narrowing issues, arranging a discovery schedule, and setting a date for trial. ( signed by Judge Allen G. Schwartz ); Copies mailed. (sac) (Entered: 07/16/1999)

ANSWER to Complaint by Venator Group (Attorney Francis X. Dee). Received in the Office of the Clerk, U.S. District Court, SDNY, on 8/31/99. (jp) (Entered: 09/02/1999)

RULE 1.9 CERTIFICATE filed by Venator Group (jp) (Entered: 09/02/1999)

STIPULATION and ORDER, the time within which EEOC may serve its responses to deft's first request for production of documents and deft's first set of interrogatories to pltff, is extended to 11/3/00 . ( signed by Judge Allen G. Schwartz ) (sn) (Entered: 01/19/2000)

STIPULATION and ORDER; that the time within which Venator Group may serve its responses to Plainitff's First Interrogatories to dft. Venator Group, Specialty, Inc. is extended to an including 12/17/99 ; plaintiff's First Request for Production of Documents to dft. Venator Group, Specialty, Inc.. be extended to and including 12/17/99 . ( signed by Judge Allen G. Schwartz ) (pl) (Entered: 01/19/2000)

Deadline(s) updated: Pltff's request for production of documents of deft Venator Group, Speciality, Inc. due for 12/17/99 . (kg) (Entered: 01/20/2000)

Deadline(s) updated: Pltff's request for production of documents of deft Venator Group, Speciality, Inc. due for 12/17/99 . (kg)

PRETRIAL SCHEDULING ORDER: the next pretrial conference will be held on 4/10/00 at 10:30 a.m.; the parties are instructed purs. to Rule 16, FRCP, to meet and pursue settlement discussions, and pltff's counsel is directed to advise Chambers. ( signed by Judge Allen G. Schwartz ); Copies mailed. (jp) (Entered: 01/27/2000)

Transcript of record of proceedings before Judge Allen G. Schwartz for the date(s) of 3/27/00 at 10:00 AM. (sn) (Entered: 07/10/2000)

NOTICE OF MOTION by Venator Group; for an order admitting pro hac vice Irving L. Hurwitz, Esq., as attny for deft, Venator Group Speciality, Inc. ; Return date not indicated. (lf) (Entered: 11/08/2000)

AFFIDAVIT of Patrick G. Brady by Venator Group in support of [9-1] motion for an order admitting pro hac vice Irving L. Hurwitz, Esq., as attny for deft, Venator Group Speciality, Inc. . (lf) (Entered: 11/08/2000)

AFFIDAVIT of Irving L. Hurwitz by Venator Group in support of [9-1] motion for an order admitting pro hac vice Irving L. Hurwitz, Esq., as attny for deft, Venator Group Speciality, Inc. (lf) (Entered: 11/08/2000)

ORDER granting [9-1] motion for an order admitting pro hac vice Irving L. Hurwitz, Esq., as attny for deft, Venator Group Speciality, Inc. A copy of this Order shall be served upon counsel of record within 7 days from the date hereof . ( signed by Judge Allen G. Schwartz ); Copies mailed. (Forwarded to Attorney Admissions Clerk) (sn) (Entered: 11/13/2000)

Supplemental AFFIDAVIT of Irving L Hurwitz by Venator Group in support of [9-1] motion for an order admitting pro hac vice Irving L. Hurwitz, Esq., as attny for deft, Venator Group Speciality, Inc. (djc) (Entered: 11/22/2000)

Order that case be referred to the Clerk of Court for assignment to a Magistrate Judge for Discovery Disputes (signed by Judge Allen G. Schwartz ) Referred to Magistrate Judge Kevin Nathaniel Fox. (lam) (Entered: 11/30/2000)

Memo-Endorsement on letter addressed to Judge Schwartz from Michael B. Ranis, dated 11/22/00; reset discovery due for 3/1/01 . ( signed by Judge Allen G. Schwartz ); Copies mailed. (pl) (Entered: 12/01/2000)

Status Conference held before Magistrate Judge Kevin Nathaniel Fox. (kw) (Entered: 01/09/2001)

Status Conference held before Magistrate Judge Kevin Nathaniel Fox. (kw)

ORDER, by 12/21/00, pltff shall serve reports of its two experts on liability; by 1/12/01, pltff shall serve reponses in full to deft's 3rd Set of Interrogatories to pltff; by 1/16/01, pltff shall serve all responses from individuals to deft's Written Questions, and Pltff shall not be permitted to pursue any claims on behalf of nay individual for whom responses to such Written Questions have not been served by that date; by 1/26/01, pltff shall serve its expert report on damages; by 2/1/01, deft shall serve its rebuttal expert reports on liability; by 2/13/01, deft shall serve its rebuttal expert report on damages; by 2/15/01, pltff shall serve any reply expert report to deft's rebuttal expert on liability on the issue of statistical analysis. The Court declines to rule at this time on the issue of whether pltff should be ordered to produce questionnaires, as well as the responses thereto, served by pltff on former employees of deft during 1999, pending the parties' attempts at informal resolution of this issue. If the parties cannot resolve this issue informally, either party may bring this issue to the Court's attention for resolution. ( signed by Magistrate Judge Kevin Nathaniel Fox ); Copies mailed. (sac) (Entered: 01/08/2001)

Letter filed by Equal Employment addressed to Mag. Judge Fox from Michael B. Ranis, dated 1/09/01, re: in response to the Court's Order received by the EEOC on 1/4/01; docket as per chambers. (lf) (Entered: 01/22/2001)

Letter filed by Venator Group addressed to Mag. Judge Fox from Francis X. Dee, dated 1/16/01, re: in opposition to Pltff EEOC's 1/9/01 letter requesting that the Court reconsider that portion of the Order, dated 12/28/00 requiring pltff to serve all responses from individuals to deft's written questions by 1/16/01, and preventing pltff from pursuing any claims on behalf of any individual for whom responses to such written questions have not been served by that date; docket as per chambers; (lf) (Entered: 01/22/2001)

ORDER; pltff has requested, in a writing dated 1/9/01, that the Court reconsider so much of its Order dated 12/28/00, as required pltff to provide deft w/ certain questionnaire responses on or before 1/16/01 and, further, limited the universe of complainants to those persons whose questionnaires had been processed by pltff and delivered to deft on or before 1/16/01; pltff's application for reconsideration is denied ; ( signed by Magistrate Judge Kevin Nathaniel Fox ); Copies mailed. (lfa) (Entered: 01/23/2001)

Discovery conference held before Magistrate Judge Kevin Fox. (kw) (Entered: 02/09/2001)

Discovery conference held before Magistrate Judge Kevin Fox. (kw)

MEMORANDUM OF LAW by Equal Employment in support of its appeal of a January 19 order by Mag. Judge Fox. (pl) (Entered: 02/06/2001)

AFFIDAVIT of Michael B. Ranis by Equal Employment Re: Appeal of Order by Mag. Judge Fox submitted on 2/1/01. (pl) (Entered: 02/06/2001)

Memo-Endorsement on letter addressed to Mag Judge Fox from Francis X. Dee, dated 1/29/01, granting deft's request for an extension of time, until 2/15/01, in which to serve its rebuttal expert report to the EEOC's expert report pertaining to management practices ( signed by Magistrate Judge Kevin Nathaniel Fox ); Copies mailed. (cd) (Entered: 02/06/2001)

Memo-Endorsement on letter addressed to Judge Schwartz from Francis X. Dee, dated 2/13/01; approving deft Venator Group, Inc.'s intent to file its papers in opposition to pltff's appeal from the 1/19/01 Order of Mag. Judge Fox, by 2/16/01 . ( signed by Judge Allen G. Schwartz ); Copies mailed. (sn) (Entered: 02/16/2001)

AFFIDAVIT of Patrick G. Brady by Venator Group in opposition to pltff's appeal from the Order of Mag. Judge Fox, dated 1/19/01. (sn) (Entered: 02/21/2001)

MEMORANDUM OF LAW by Venator Group in opposition to pltff's appeal from the 1/19/01 Order of the Hon. Kevin Nathaniel Fox. (sn) (Entered: 02/21/2001)

Memo-Endorsement on letter addressed to Judge Schwartz from Francis X. Dee, dated 03/02/01; Re: approving counsel to defendants' request for an adjournment of certain dates as set forth herein: reset pre-trial conference for 3/26/01 ; reset pre-trial order due for 3/26/01 ; Deposition of Thomas Mahoney - 03/02/01; Deposition of Brian Sullivan (continuation) - 03/02/01; Deposition of Bernard Siskin - 03/06/01; Deposition of Janice Madden - 03/09/01; Deposition of Frank Landy - 03/13/01 ; ( signed by Judge Allen G. Schwartz ); Copies mailed. (djc) (Entered: 03/06/2001)

Memo-Endorsement on letter addressed to Judge Schwartz from Francis X. Dee, dated 3/2/01; granting counsel for deft's request that the pretrial conference be adjourned until 3/26/01; and that the deadline for submission of the parties' joint final pretrial order be extended until 3/26/01 . ( signed by Judge Allen G. Schwartz ); Copies mailed. (sn) (Entered: 03/08/2001)

MEMORANDUM ORDER, for the foregoing reasons, the Court affirms the conclusions set forth in Judge Fox's 12/28/00 Order, and denial of EEOC's reconsideration motion on 1/19/01 ; however, in light of the recent extension of the discovery deadline to the end of 3/01, the Court directs that all individuals whose questionnaire responses have been served upon deft by the date of this Order be considered claimants in this action ( signed by Judge Allen G. Schwartz ); Copies mailed. (cd) Modified on 03/14/2001 (Entered: 03/14/2001)

Memo-Endorsement on letter addressed to Judge Schwartz from Michael B. Ranis, dated 03/23/01; reset submission of the joint pre-trial order and jury instructions due for 4/9/01 (signed by Judge Allen G. Schwartz ); Copies mailed. (djc) (Entered: 03/26/2001)

NOTICE OF MOTION (filed on service date) by Equal Employment; for an order to bifurcate trial into Stage I and Stage II proceedings ; w/ attch. Memorandum in support; Return date: not indicated. (pl) (Entered: 04/17/2001)

NOTICE OF MOTION (filed on service date) by Equal Employment; for an order in limine to introduce evidence regarding inaccuracies in dft.'s Computerized Data ; Return date: not indicated. (pl) (Entered: 04/17/2001)

NOTICE OF MOTION (filed on service date) by Equal Employment; for an order to amend the Expert Report of Dr. Janice Madden ; Return date: not indicated. (pl) (Entered: 04/17/2001)

EEOC's PROPOSED VERDICT SHEET (pl) (Entered: 04/17/2001)

Proposed Voir Dire Questions by Venator Group (pl) (Entered: 04/17/2001)

Defendant's Proposed Verdict Sheet (pl) (Entered: 04/17/2001)

Proposed Jury Charges on substantive Law by Venator Group (pl) (Entered: 04/17/2001)

Proposed Jury Instructions by Equal Employment (pl) (Entered: 04/17/2001)

Plaintiff EEOC's Voir Dire Questions (pl) (Entered: 04/17/2001)

Joint Proposed Jury Charges by Equal Employment, Venator Group (pl) (Entered: 04/17/2001)

Plaintiff's Pre-Trial Brief (pl) (Entered: 04/17/2001)

Joint Pretrial Order (pl) (Entered: 04/17/2001)

JOINT PRETRIAL ORDER filed by the parties. ( signed by Judge Allen G. Schwartz ) (jp) (Entered: 04/18/2001)

ORDER, that by 5/3/01, the parties shall submit to the Court one copy of each transcript, slated to be used at trial, in which the disputed testimony appears ( signed by Magistrate Judge Kevin Nathaniel Fox ); Copies mailed. (lam) (Entered: 04/25/2001)

MEMORANDUM OF LAW by Venator Group in opposition to [31-1] motion for an order in limine to introduce evidence regarding inaccuracies in dft.'s Computerized Data . (cd) (Entered: 05/03/2001)

AFFIDAVIT of Patrick G. Brady by Venator Group in opposition to [31-1] motion for an order in limine to introduce evidence regarding inaccuracies in dft.'s Computerized Data (cd) (Entered: 05/03/2001)

NOTICE OF MOTION (FILED ON SERVICE DATE) by Venator Group purs. to Rule 56 of the F.R.C.P., for an order granting partial summary judgment in favor of deft with respect to certain individual claimants for whom defts did not receive signed, sworn responses to deft's written questions by 3/12/01 . No return date indicated. (Rec'd in night deposit box 5/8/01 7:09 PM) (sn) Modified on 05/11/2001 (Entered: 05/11/2001)

AFFIDAVIT of Patrick G. Brady by Venator Group in support of [46-1] motion for an order granting partial summary judgment in favor of deft with respect to certain individual claimants for whom defts did not receive signed, sworn responses to deft's written questions by 3/12/01. (sn) (Entered: 05/11/2001)

MEMORANDUM OF LAW by Venator Group in support of [46-1] motion for an order granting partial summary judgment in favor of deft with respect to certain individual claimants for whom defts did not receive signed, sworn responses to deft's written questions by 3/12/01. (sn) (Entered: 05/11/2001)

RULE 56.1 STATEMENT filed by Venator Group, in support of deft's motion for partial summary judgment with respect to certain individual claimants. (sn) Modified on 05/11/2001 (Entered: 05/11/2001)

NOTICE OF MOTION (FILED ON SERVICE DATE) by Venator Group purs. to Rule 56 of the F.R.C.P. for an order granting partial summary judgment in favor of deft dismissing all claims as to defts Edwin Alemany, Clarence Emanuel, Federico Grimany, Cornelius Guider, Wayne Hanson, Francis Lobasso, Jr., and Donald Russell ; or alternatively, to sever their claims . No return date indicated. (Rec'd in night deposit box 5/8/01 7:01 PM) (sn) (Entered: 05/11/2001)

AFFIDAVIT of Patrick G. Brady by Venator Group in support of [50-1] motion purs. to Rule 56 of the F.R.C.P. for an order granting partial summary judgment in favor of deft dismissing all claims as to defts Edwin Alemany, Clarence Emanuel, Federico Grimany, Cornelius Guider, Wayne Hanson, Francis Lobasso, Jr., and Donald Russell; [50-2] motion to sever their claims. (Rec'd in night deposit box 5/8/01 7:02 PM) (sn) (Entered: 05/11/2001)

AFFIDAVIT of Peter Clay by Venator Group in support of [46-1] motion purs. to Rule 56 of the F.R.C.P., for an order granting partial summary judgment in favor of deft with respect to certain individual claimants for whom defts did not receive signed, sworn responses to deft's written questions by 3/12/01; [50-1] motion purs. to Rule 56 of the F.R.C.P. for an order granting partial summary judgment in favor of deft dismissing all claims as to defts Edwin Alemany, Clarence Emanuel, Federico Grimany, Cornelius Guider, Wayne Hanson, Francis Lobasso, Jr., and Donald Russell; [50-2] motion to sever their claims. (Rec'd in night deposit box 5/8/01 7:02 PM) (sn) Modified on 05/11/2001 (Entered: 05/11/2001)

MEMORANDUM OF LAW by Venator Group in support of [50-1] motion purs. to Rule 56 of the F.R.C.P. for an order granting partial summary judgment in favor of deft dismissing all claims as to defts Edwin Alemany, Clarence Emanuel, Federico Grimany, Cornelius Guider, Wayne Hanson, Francis Lobasso, Jr., and Donald Russell; [50-2] motion to sever their claims. (Rec'd in night deposit box 5/8/01 7:02 PM) (sn) (Entered: 05/11/2001)

RULE 56.1 STATEMENT filed by Venator Group, in support of deft's motion for partial summary judgment with respect to certain individual store manager claimants. (Rec'd in night deposit box 5/8/01 7:02 PM) (sn) (Entered: 05/11/2001)

NOTICE OF MOTION (FILED ON SERVICE DATE) by Venator Group purs. to Rule 56 of the F.R.C.P., for an order granting partial summary judgment in favor of deft with respect to pltff's complaint, insofar as it alleges that deft engaged in a "Pattern and Practice" of discrimination . No return date indicated. (Rec'd in night deposit box 5/8/01 6:56 PM) (sn) (Entered: 05/11/2001)

AFFIDAVIT of Patrick G. Brady by Venator Group in support of [55-1] motion purs. to Rule 56 of the F.R.C.P., for an order granting partial summary judgment in favor of deft with respect to pltff's complaint, insofar as it alleges that deft engaged in a "Pattern and Practice" of discrimination. (Rec'd in night deposit box 5/8/01 6:57 PM) (sn) (Entered: 05/11/2001)

MEMORANDUM OF LAW by Venator Group in support of [55-1] motion purs. to Rule 56 of the F.R.C.P., for an order granting partial summary judgment in favor of deft with respect to pltff's complaint, insofar as it alleges that deft engaged in a "Pattern and Practice" of discrimination. (Rec'd in night deposit box 5/8/01 6:57 PM) (sn) (Entered: 05/11/2001)

RULE 56.1 STATEMENT filed by Venator Group, in support of deft's motion for partial summary judgment as to pltff's pattern and practice claim. (Rec'd in night deposit box 5/8/01 6:57 PM) (sn) (Entered: 05/11/2001)

NOTICE OF MOTION (FILED ON SERVICE DATE) by Venator Group purs. to Rule 56 of the F.R.C.P., for an order granting summary judgment in favor of deft with respect to pltff's complaint, in its entirety, as barred by the applicable 90-day statute of limitations, 29 U.S.C. Sec. 626(e) . No return date indicated.. (Rec'd in night deposit box 5/8/01 7:05 PM) (sn) (Entered: 05/11/2001)

AFFIDAVIT of Patrick G. Brady by Venator Group in support of [59-1] motion purs. to Rule 56 of the F.R.C.P., for an order granting summary judgment in favor of deft with respect to pltff's complaint, in its entirety, as barred by the applicable 90-day statute of limitations, 29 U.S.C. Sec. 626(e). (Rec'd in night deposit box 5/8/01 7:06 PM) (sn) (Entered: 05/11/2001)

MEMORANDUM OF LAW by Venator Group in support of [59-1] motion purs. to Rule 56 of the F.R.C.P., for an order granting summary judgment in favor of deft with respect to pltff's complaint, in its entirety, as barred by the applicable 90-day statute of limitations, 29 U.S.C. Sec. 626(e). (Rec'd in night deposit box 5/8/01 7:06 PM) (sn) (Entered: 05/11/2001)

RULE 56.1 STATEMENT filed by Venator Group, in support of deft's motion for summary judgment dismissing the complaint in its entirety as barred by the applicable 90-day statute of limitations. (Rec'd in night deposit box 5/8/01 7:06 PM) (sn) (Entered: 05/11/2001)

NOTICE OF MOTION by Venator Group for an order, granting deft's motion in limine regarding certain evidentiary issues, and precluding pltff from introducing lay opinion testimony that deft's actions were motivated by age consideration; precluding pltff from introducing as exhibits in its case in chief any expert reports; precluding pltff from introducing as exhibits in its case-in-chief any responses to deft's written questions, or any charges of discrimination ; Return date not indicated. (rec'd in the night deposit box on 5/15/01 at 7:41 p.m.) (sac) Modified on 05/18/2001 (Entered: 05/18/2001)

MEMORANDUM OF LAW by Venator Group in support of [63-1] motion for an order, granting deft's motion in limine regarding certain evidentiary issues, and precluding pltff from introducing lay opinion testimony that deft's actions were motivated by age consideration; precluding pltff from introducing as exhibits in its case in chief any expert reports; precluding pltff from introducing as exhibits in its case-in-chief any responses to deft's written questions, or any charges of discrimination. (rec'd in the night deposit box on 5/15/01 at 7:41 p.m.) (sac) (Entered: 05/18/2001)

NOTICE OF MOTION by Venator Group for an order, precluding the testimony or reports of the EEOC's proposed Human Resources Management expert, Thomas A. Mahoney ; Return date not indicated. (sac) (Entered: 05/18/2001)

MEMORANDUM OF LAW by Venator Group in support of [65-1] motion for an order, precluding the testimony or reports of the EEOC's proposed Human Resources Management expert, Thomas A. Mahoney. (rec'd in the night deposit box on 5/15/01 at 7:32 p.m.) (sac) (Entered: 05/18/2001)

AFFIDAVIT of Partick G. Brady by Venator Group in support of [65-1] motion for an order, precluding the testimony or reports of the EEOC's proposed Human Resources Management expert, Thomas A. Mahoney. (rec'd in the night deposit box on 5/15/01 at 7:32 p.m.) (sac) (Entered: 05/18/2001)

NOTICE OF MOTION by Venator Group for an order, precluding ptlff from presenting at trial the testimony and reports of pltff's statistical and economic damages expert, Janice Fanning Madden, Ph.D. ; Return date not indicated. (rec'd in the night deposit box on 5/15/01 at 7:35 p.m.) (sac) (Entered: 05/18/2001)

MEMORANDUM OF LAW by Venator Group in support of [68-1] motion for an order, precluding ptlff from presenting at trial the testimony and reports of pltff's statistical and economic damages expert, Janice Fanning Madden, Ph.D. (rec'd in the night deposit box on 5/15/01 at 7:35 p.m.) (sac) (Entered: 05/18/2001)

AFFIDAVIT of Partick G. Brady by Venator Group in support of [68-1] motion for an order, precluding ptlff from presenting at trial the testimony and reports of pltff's statistical and economic damages expert, Janice Fanning Madden, Ph.D. (rec'd in the night deposit box on 5/15/01 at 7:35 p.m.) (sac) (Entered: 05/18/2001)

MEMORANDUM OF LAW by Venator Group in opposition to [30-1] motion for an order to bifurcate trial into Stage I and Stage II proceedings. (rec'd in the night deposit box on 5/15/01 at 7:40 p.m.) (sac) (Entered: 05/18/2001)

AFFIDAVIT of Patrick G. Brady by Venator Group in opposition to [30-1] motion for an order to bifurcate trial into Stage I and Stage II proceedings. (rec'd in the night deposit box on 5/15/01 at 7:40 p.m.) (sac) (Entered: 05/18/2001)

Transcript of record of proceedings before Judge Allen G. Schwartz for the date(s) of 4/17/01. (gmo) (Entered: 05/31/2001)

MEMORANDUM OF LAW by Equal Employment in opposition to [55-1] motion purs. to Rule 56 of the F.R.C.P., for an order granting partial summary judgment in favor of deft with respect to pltff's complaint, insofar as it alleges that deft engaged in a "Pattern and Practice" of discrimination . (cd) (Entered: 06/12/2001)

MEMORANDUM OF LAW by Equal Employment in opposition to [59-1] motion purs. to Rule 56 of the F.R.C.P., for an order granting summary judgment in favor of deft with respect to pltff's complaint, in its entirety, as barred by the applicable 90-day statute of limitations, 29 U.S.C. Sec. 626(e) . (cd) (Entered: 06/12/2001)

MEMORANDUM OF LAW by Equal Employment in opposition to [55-1] motion purs. to Rule 56 of the F.R.C.P., for an order granting partial summary judgment in favor of deft with respect to pltff's complaint, insofar as it alleges that deft engaged in a "Pattern and Practice" of discrimination . (cd) (Entered: 06/12/2001)

MEMORANDUM OF LAW by Equal Employment in opposition to [59-1] motion purs. to Rule 56 of the F.R.C.P., for an order granting summary judgment in favor of deft with respect to pltff's complaint, in its entirety, as barred by the applicable 90-day statute of limitations, 29 U.S.C. Sec. 626(e) . (cd) (Entered: 06/12/2001)

AFFIDAVIT of Michael B. Ranis by Equal Employment Re: [77-1] opposition memorandum, [76-1] opposition memorandum, [75-1] opposition memorandum, [74-1] opposition memorandum . (cd) (Entered: 06/12/2001)

AFFIDAVIT of Michael B. Ranis by Equal Employment Re: [77-1] opposition memorandum, [76-1] opposition memorandum, [75-1] opposition memorandum, [74-1] opposition memorandum . (cd) (Entered: 06/12/2001)

RULE 56.1 STATEMENT filed by Equal Employment (cd) (Entered: 06/12/2001)

RULE 56.1 STATEMENT filed by Equal Employment (cd) (Entered: 06/12/2001)

RULE 56.1 STATEMENT filed by Equal Employment (cd) (Entered: 06/12/2001)

RULE 56.1 STATEMENT filed by Equal Employment (cd) (Entered: 06/12/2001)

AFFIDAVIT of Michael Ranis by Equal Employment in support of [83-1] settlement notice . (cd) (Entered: 06/12/2001)

REPLY MEMORANDUM of LAW by Venator Group in Further Support of [55-1] motion purs. to Rule 56 of the F.R.C.P., for an order granting partial summary judgment in favor of deft with respect to pltff's complaint, insofar as it alleges that deft engaged in a "Pattern and Practice" of discrimination. (djc) (Entered: 06/20/2001)

SUPPLEMENTAL AFFIDAVIT of Patrick G. Brady by Venator Group in support of [55-1] motion purs. to Rule 56 of the F.R.C.P., for an granting partial summary judgment in favor of deft with respect to pltff's complaint, insofar as it alleges that deft engaged in a "Pattern and Practice" of discrimination (djc) (Entered: 06/20/2001)

REPLY MEMORANDUM of LAW by Venator Group in Support of [46-1] motion purs. to Rule 56 of the F.R.C.P., for an order granting partial summary judgment in favor of deft with respect to certain individual claimants for whom defts did not receive signed, sworn responses to deft's written questions by 3/12/01 (djc) (Entered: 06/20/2001)

REPLY MEMORANDUM of LAW by Venator Group re: in Further Support of its Motion for Summary Judgment Dismissing the Complaint as Barred by the Applicable Ninety-day Statute of Limitations. (djc) (Entered: 06/20/2001)

REPLY MEMORANDUM of LAW by Venator Group in Further Support of Defendants' Motion for Partial Summary Judgment with respect to the Claims of Certain Individual Store Managers; (djc) (Entered: 06/20/2001)

SUPPLEMENTAL AFFIDAVIT of Peter Clay by Venator Group in support of [55-1] motion purs. to Rule 56 of the F.R.C.P., for an granting partial summary judgment in favor of deft with respect to pltff's complaint, insofar as it alleges that deft engaged in a "Pattern and Practice" of discrimination, [50-1] motion purs. to Rule 56 of the F.R.C.P. for an order granting partial summary judgment in favor of deft dismissing all claims as to defts Edwin Alemany, Clarence Emanuel, Federico Grimany, Cornelius Guider, Wayne Hanson, Francis Lobasso, Jr., and Donald Russell; and to supplement affidavit dated May 7, 2001. (djc) (Entered: 06/20/2001)

SUPPLEMENTAL AFFIDAVIT of Patrick G. Brady by Venator Group in support of defendants' motion for partial summary judgment with respect to certain individual store manager claims; (djc) (Entered: 06/20/2001)

RULE 56.1 STATEMENT filed by Venator Group (djc) (Entered: 06/20/2001)