United States Equal Employment Opportunity Commission v. Worthington, Moore & Jacobs, Inc.

EEOC v. Worthington, Moore & Jacobs, Inc.

EEOC v. Worthington, Moore & Jacobs, Inc.

EEOC v. Worthington, Moore & Jacobs, Inc.

EEOC v. Worthington, Moore & Jacobs, Inc.

EEOC v. Worthington, Moore & Jacobs, Inc.

EEOC v. Worthington, Moore & Jacobs, Inc.

EEOC v. Worthington, Moore & Jacobs, Inc.

Carly Knight, Frank Dobbin, Alexandra Kalev

COMPLAINT against Worthington, Moore &Jacobs, Inc. , filed by United States Equal Employment Opportunity Commission. (Attachments: # 1 Civil Cover Sheet)(raf, Deputy Clerk) (Entered: 10/01/2004)

JURY TRIAL DEMAND by United States Equal Employment Opportunity Commission. (raf, Deputy Clerk) (Entered: 10/01/2004)

Summons Issued (20 days) as to Worthington, Moore &Jacobs, Inc.. (raf, Deputy Clerk) (Entered: 10/01/2004)

SUMMONS Returned Executed by United States Equal Employment Opportunity Commission. Worthington, Moore &Jacobs, Inc. served on 1/20/2005, answer due 2/9/2005. (Morocco, Maria) (Entered: 01/25/2005)

MOTION to Intervene by Laura Thomas. Responses due by 2/20/2005 (Attachments: # 1 Exhibit A)(Relman, John) (Entered: 02/03/2005)

NOTICE by Laura Thomas of Service of Motion to Intervene (Relman, John) (Entered: 02/03/2005)

MOTION to Dismiss /Motion for Summary Judgment by Worthington, Moore &Jacobs, Inc.. Responses due by 2/26/2005 (Attachments: # 1 Memorandum in Support of Motion# 2 Exhibit List# 3 Exhibits 1 through 9# 4 Exhibit 10# 5 Text of Proposed Order)(Phelan, Jeanne) (Entered: 02/09/2005)

ORDER granting 4 Motion of Laura Thomas to Intervene. Signed by Judge Benson E Legg on 2/24/05. (mcb, Deputy Clerk) (Entered: 02/25/2005)

Intervenor COMPLAINT with Jury Demand, filed by Laura Thomas.(mcb, Deputy Clerk) (Entered: 02/25/2005)

Consent MOTION for Extension of Time to File Response/Reply as to 6 MOTION to Dismiss /Motion for Summary Judgment by United States Equal Employment Opportunity Commission. Responses due by 3/14/2005 (Attachments: # 1)(Morocco, Maria) (Entered: 02/25/2005)

PAPERLESS ORDER GRANTING re 9 Consent MOTION for Extension of Time to File Response/Reply as to 6 MOTION to Dismiss /Motion for Summary Judgment Responses due by 3/10/2005. Replies due by 4/1/2005. Signed by Judge Benson E Legg on 2/28/2005. (Legg, Benson) (Entered: 02/28/2005)

RESPONSE in Opposition re 6 MOTION to Dismiss /Motion for Summary Judgment filed by United States Equal Employment Opportunity Commission. Replies due by 3/24/2005. (Attachments: # 1)(Morocco, Maria) (Entered: 03/10/2005)

ANSWER to Intervenor Complaint by Worthington, Moore &Jacobs, Inc..(Phelan, Jeanne) (Entered: 03/16/2005)

REPLY to Response to Motion re 6 MOTION to Dismiss /Motion for Summary Judgment filed by Worthington, Moore &Jacobs, Inc.. (Phelan, Jeanne) (Entered: 04/01/2005)

RESPONSE in Opposition re 14 MOTION for Leave to File Surreply filed by Worthington, Moore &Jacobs, Inc.. Replies due by 5/16/2005. (Attachments: # 1 Response to EEOC's Surreply Brief)(Phelan, Jeanne) (Entered: 05/02/2005)

SCHEDULING ORDER: Status Report due by 9/30/2005. Signed by Judge Benson Everett Legg on 5/18/05. (mcb, Deputy Clerk) (Entered: 05/19/2005)

MEMORANDUM. Signed by Judge Benson Everett Legg on 5/18/05. (mcb, Deputy Clerk)

ORDER denying without Prejudice 6 Motion of Defendant to Dismiss, or, in the Alternative, Motion for Summary Judgment; and, denying 14 Motion of Plaintiff for Leave to File a Surreply. Signed by Judge Benson Everett Legg on 5/18/05. (mcb, Deputy Clerk) (Entered: 05/19/2005)

MOTION for Kelly M. Baldrate to Appear Pro Hac Vice by Laura Thomas. (mcb, Deputy Clerk) (Entered: 05/26/2005)

MARGINAL ORDER granting 19 Motion of Plaintiff−Intervenor, Laura Thomas for Kelly M. Baldrate to Appear Pro Hac Vice (Fee paid Receipt #14637002216 − for Document #20 see #19). Signed by Clerk on 5/26/05. (mcb, Deputy Clerk) (Entered: 05/26/2005)

MOTION for Jennifer I. Klar to Appear Pro Hac Vice by Laura Thomas. (jnl, Deputy Clerk) (Entered: 05/27/2005)

MARGINAL ORDER granting 21 Motion of plaintiff to Appear Pro Hac Vice (fee pd). Signed by Deputy Clerk on 5/26/05. (For #22, see #21) (jnl, Deputy Clerk) (Entered: 05/27/2005)

MOTION to Intervene As Plaintiff by Nancy Guzman. Responses due by 6/17/2005 (Attachments: # 1 Memorandum# 2 Complaint# 3 Exhibit (Ex. 1 to Complaint)# 4 Text of Proposed Order)(Jefferson, Anna) (Entered: 05/31/2005)

Report re: Deposition hours (Relman, John) (Entered: 06/01/2005)

ORDER AUTHORIZING 15 deposition hours per side as therein set forth. Signed by Judge Benson Everett Legg on 6/1/05. (mcb, Deputy Clerk) (Entered: 06/02/2005)

ANSWER to Complaint by Worthington, Moore &Jacobs, Inc..(Phelan, Jeanne) (Entered: 06/02/2005)

ORDER granting 23 Motion of Nancy Guzman to Intervene. Signed by Judge Benson Everett Legg on 6/22/05. (mcb, Deputy Clerk) (Entered: 06/23/2005)

Intervenor COMPLAINT, filed by Nancy Guzman. (Attachments: # 1 Exhibit EEOC Determination)(Jefferson, Anna) (Entered: 06/23/2005)

ANSWER to Intervenor Complaint by Worthington, Moore &Jacobs, Inc..(Phelan, Jeanne) (Entered: 07/06/2005)

Consent MOTION for Extension of Time to Complete Discovery by Intervenors and by United States Equal Employment Opportunity Commission. Responses due by 8/1/2005 (Attachments: # 1)(Morocco, Maria) (Entered: 07/15/2005)

PAPERLESS ORDER granting 30 Motion for Extension of Time to Complete Discovery. Signed by Judge Benson Everett Legg on 07/18/2005. (Legg, Benson Everett) (Entered: 07/18/2005)

Consent MOTION for Protective Order by Worthington, Moore &Jacobs, Inc.. Responses due by 8/29/2005 (Attachments: # 1 Text of Proposed Order)(Phelan, Jeanne) (Entered: 08/11/2005)

NOTICE of service of motion to compel discovery by United States Equal Employment Opportunity Commission (Attachments: # 1 # 2)(Morocco, Maria)

NOTICE of service of response to motion to compel discovery by Worthington, Moore &Jacobs, Inc. re 33 Notice of service of motion to compel discovery by Plaintiff EEOC (Attachments: # 1 Opposition to Plaintiff's Motion to Compel Answer to Interrogatory No. 3)(Phelan, Jeanne) (Entered: 09/19/2005)

NOTICE of service of reply to response to motion to compel discovery by United States Equal Employment Opportunity Commission (Attachments: # 1)(Morocco, Maria) (Entered: 09/28/2005)

NOTICE of service of motion to compel discovery by Nancy Guzman (Attachments: # 1 Motion to Compel)(Jefferson, Anna) (Entered: 10/06/2005)

MOTION to Compel Identification of Witnesses in Response to Interrogatory No. 3 by United States Equal Employment Opportunity Commission. Responses due by 10/24/2005 (Morocco, Maria) (Entered: 10/07/2005)

MOTION for Leave to File Amended Complaint by Nancy Guzman. Responses due by 11/10/2005 (Attachments: # 1 Exhibit `# 2 Exhibit 2# 3 Text of Proposed Order Exhibit 3)(Lebau, Stephen) (Entered: 10/24/2005)

NOTICE of service of response to motion to compel discovery by Worthington, Moore &Jacobs, Inc. re 37 Notice of service of motion to compel discovery by Intervenor Guzman (Attachments: # 1 Opposition to Intervenor Guzman's Motion to Compel Discovery)(Phelan, Jeanne) (Entered: 10/26/2005)

Joint MOTION for Extension of Time to Complete Discovery by United States Equal Employment Opportunity Commission. Responses due by 11/18/2005 (Attachments: # 1)(Morocco, Maria) (Entered: 11/01/2005)

MOTION for Other Relief limine motion by Nancy Guzman. Responses due by 11/21/2005 (Attachments: # 1 Exhibit EX 1 motion to compel# 2 Exhibit Ex 2 − Def. Supp. Responses)(Lebau, Stephen) (Entered: 11/02/2005)

RESPONSE in Opposition re 39 MOTION for Leave to File Amended Complaint by Intervenor Guzman filed by Worthington, Moore &Jacobs, Inc.. Replies due by 11/28/2005. (Attachments: # 1 Exhibit 1# 2 Exhibit 2)(Phelan, Jeanne) (Entered: 11/10/2005)

REPLY to Response to Motion re 39 MOTION for Leave to File Amended Complaint filed by Nancy Guzman. (Attachments: # 1 Exhibit EXHIBIT 1)(Lebau, Stephen) (Entered: 11/11/2005)

ORDER SETTING date for teleconference. Signed by Judge Benson Everett Legg on 11/15/05. (hml, Deputy Clerk) (Entered: 11/16/2005)

MOTION to Compel Deposition Testimony by United States Equal Employment Opportunity Commission. Responses due by 12/5/2005 (Attachments: # 1 # 2 # 3 # 4)(Morocco, Maria) (Additional attachment(s) added on 11/22/2005 to replace original exhibits that did not scan properly) (mcb, Deputy Clerk). Modified on 11/22/2005 (mcb, Deputy Clerk). (Entered: 11/18/2005)

NOTICE by United States Equal Employment Opportunity Commission re 42 MOTION for Other Relief limine motion (Morocco, Maria) (Entered: 11/18/2005)

Correspondence re: teleconference on 11.22.05 (Lebau, Stephen) (Entered: 11/18/2005)

RESPONSE in Opposition re 42 MOTION for Other Relief limine motion /motion to disqualify counsel filed by Worthington, Moore &Jacobs, Inc.. Replies due by 12/5/2005. (Attachments: # 1 Exhibit 3# 2 Exhibit 4# 3 Exhibit 5# 4 Exhibit 6# 5 Exhibit 7# 6 Exhibit 8# 7 Exhibit 9)(Phelan, Jeanne) (Entered: 11/21/2005)

ORDER granting in part and denying in part 38 Motion to Compel, granting 39 Motion for Leave to Amend Complaint, granting 41 Motion for Extension of Time to Complete Discovery, denying 42 Motion to Disqualify, granting 46 Motion to Compel deposition testimony as thererin set forth. Signed by Judge Benson Everett Legg on 11/22/05. (mcb, Deputy Clerk) (Entered: 11/23/2005)

Telephone Conference held on 11/22/2005 held before Chief Judge Benson Everett Legg. (Recorded on Tape) (kam, Deputy Clerk) (Entered: 12/12/2005)

MOTION for Protective Order by Nancy Guzman. Responses due by 12/13/2005 (Lebau, Stephen) (Entered: 11/26/2005)

ANSWER to Complaint by Worthington, Moore &Jacobs, Inc..(Phelan, Jeanne) (Entered: 12/05/2005)

RESPONSE in Opposition re 51 MOTION for Protective Order filed by Worthington, Moore &Jacobs, Inc.. Replies due by 12/27/2005. (Phelan, Jeanne) (Entered: 12/13/2005)

MOTION to Dismiss just COUNT III, COBRA claim by Nancy Guzman. Responses due by 1/9/2006 (Attachments: # 1 Exhibit alleged COBRA notice# 2 Exhibit 2 − 4th Cir case# 3 Exhibit 3 dismissal communications# 4 Text of Proposed Order order)(Lebau, Stephen) (Entered: 12/21/2005)

Joint MOTION for Extension of Time to Complete Discovery by United States Equal Employment Opportunity Commission, Worthington, Moore &Jacobs, Inc.. Responses due by 1/9/2006 (Attachments: # 1 Text of Proposed Order)(Phelan, Jeanne) (Entered: 12/22/2005)

PAPERLESS ORDER GRANTING 55 Joint Motion for Extension of Time to Complete Discovery to 1/13/2006. Signed by Judge Benson Everett Legg on 12/23/05. (Legg, Benson Everett) (Entered: 12/23/2005)

REPLY to Response to Motion re 51 MOTION for Protective Order filed by Nancy Guzman. (Lebau, Stephen) (Entered: 12/27/2005)

Correspondence re: Discovery/Dep. of Defense Counsel (Lebau, Stephen) (Entered: 01/12/2006)

SEALED MOTION for Discovery (To Compel Answers to Deposition Questions) by Worthington, Moore &Jacobs, Inc.. Responses due by 1/30/2006 (Attachments: # 1 Memorandum in Support of Motion# 2 Exhibit 1# 3 Exhibit 2# 4 Exhibit 3)(Phelan, Jeanne) MOTION for Discovery (To Compel Answers to Deposition Questions) by Worthington, Moore &Jacobs, Inc.. Responses due by 1/30/2006 (Attachments: # 1 Memorandum in Support of Motion# 2 Exhibit 1# 3 Exhibit 2# 4 Exhibit 3)(Phelan, Jeanne) Modified on 1/18/2006 (hml, Deputy Clerk). Modified on 2/16/2006 (cags, Deputy Clerk) (Entered: 01/12/2006)

ORDER granting 54 Unopposed Motion of Ms. Guzman to Dismiss her COBRA claim.. Signed by Judge Benson Everett Legg on 1/13/06. (mcb, Deputy Clerk) (Entered: 01/13/2006)

STATUS REPORT by United States Equal Employment Opportunity Commission. (Morocco, Maria) (Entered: 01/13/2006)

MOTION to Seal Defendant's Motion to Compel Deposition Testimony and Related Filings by Laura Thomas. Responses due by 2/6/2006 (Attachments: # 1 Text of Proposed Order)(Relman, John) (Entered: 01/18/2006)

RESPONSE in Opposition re 59 MOTION for Discovery (To Compel Answers to Deposition Questions) (memorandum in support filed seperately under seal) filed by Laura Thomas. Replies due by 2/1/2006. (Attachments: # 1 Text of Proposed Order)(Relman, John) (SEALED DOCUMENT REC'D 1/18/06) Modified on 1/18/2006 (hml, Deputy Clerk). (Entered: 01/18/2006)

NOTICE by Worthington, Moore &Jacobs, Inc. re 63 Response in Opposition to Motion, filed under temporary seal (Phelan, Jeanne) (Entered: 02/01/2006)

ORDER SETTING date for a Teleconference. Signed by Judge Benson Everett Legg on 2/28/06. (mcb, Deputy Clerk) (Entered: 02/28/2006)

SEALED Telephone Conference held on 3/3/2006 held before Judge Benson Everett Legg. (Recorded on Tape) (kam, Deputy Clerk) (Entered: 03/10/2006)

Consent MOTION for Extension of Time to file summary judgment briefs by United States Equal Employment Opportunity Commission. Responses due by 3/30/2006 (Attachments: # 1)(Morocco, Maria) (Entered: 03/13/2006)

PAPERLESS ORDER granting 67 Motion for Extension of Time. Signed by Judge Benson Everett Legg on 03/14/2006. (Legg, Benson Everett) (Entered: 03/14/2006)

STIPULATION Regarding Confidentiality of Portions of the Deposition Testimony of Intervenor Laura Thomas by Laura Thomas. (Relman, John) (Entered: 03/25/2006)

STIPULATED ORDER Regarding Confidentiality of Portions of the Deposition Testimony of Intervenor Laura Thomas (Local Rule 104.13). Signed by Judge Benson Everett Legg on 3/27/06. (mcb, Deputy Clerk) (Entered: 03/27/2006)

PAPERLESS ORDER denying as moot 51 Motion for Protective Order. Signed by Judge Benson Everett Legg on 03/28/2006. (Legg, Benson Everett) (Entered: 03/28/2006)

PAPERLESS ORDER granting 62 Motion to Seal. Signed by Judge Benson Everett Legg on 03/28/2006. (Legg, Benson Everett) (Entered: 03/28/2006)

Consent MOTION for Extension of Time to File Dispositive Motion and Responses by Worthington, Moore &Jacobs, Inc.. Responses due by 5/8/2006 (Attachments: # 1 Text of Proposed Order)(Phelan, Jeanne) (Entered: 04/19/2006)

PAPERLESS ORDER granting 73 Motion for Extension of Time. Signed by Judge Benson Everett Legg on 04/19/2006. (Legg, Benson Everett) (Entered: 04/19/2006)

(FILED IN ERROR − HAS REFILED − SEE #78) MOTION for Partial Summary Judgment by Worthington, Moore &Jacobs, Inc. Responses due by 5/16/2006 (Attachments: # 1 Memorandum In Support of Motion (UNLINKED) # 2 Notice of Filing Lengthy Exhibits)(Phelan, Jeanne) Modified on 5/1/2006 (mcb, Deputy Clerk). (Entered: 04/29/2006)

Consent MOTION for Leave to file Revised Memorandum in Support to 75 MOTION for Partial Summary Judgment by Worthington, Moore &Jacobs, Inc. Responses due by 5/18/2006 (Attachments: # 1 Memorandum in Support of Motion for Partial Summary Judgment (revised)# 2 Text of Proposed Order)(Phelan, Jeanne) Modified on 5/1/2006 (mcb, Deputy Clerk. (Entered: 05/01/2006)

PAPERLESS ORDER granting 76 Consent Motion for Leave to File. The Clerk will be instructed to UNLINK the Memorandum to 75 Motion for Partial Summary Judgment and the defendant shall refile the revised memorandum today. Signed by Judge Benson Everett Legg on 05/01/2006. (Legg, Benson Everett) Modified on 5/1/2006 (mcb, Deputy Clerk). (Entered: 05/01/2006)

MOTION for Partial Summary Judgment by Worthington, Moore &Jacobs, Inc.. Responses due by 5/19/2006 (Attachments: # 1 Memorandum In Support# 2 Notice of Filing Lengthy Exhibits)(Phelan, Jeanne) (Entered: 05/02/2006)

MOTION to Withdraw as Attorney Kelly M. Baldrate by Laura Thomas. Responses due by 5/22/2006 (Relman, John) (Entered: 05/03/2006)

PAPERLESS ORDER granting 79 Motion to Withdraw as Attorney. Attorney Kelly Marie Baldrate terminated. Signed by Judge Benson Everett Legg on 5/4/06. (jnl, Deputy Clerk) (Entered: 05/05/2006)

Consent MOTION for Extension of Time to File Response/Reply as to 78 MOTION for Partial Summary Judgment by United States Equal Employment Opportunity Commission. Responses due by 5/26/2006 (Morocco, Maria)

Consent MOTION for Extension of Time to File Response/Reply as to 78 MOTION for Partial Summary Judgment (Two Day Extension) by Laura Thomas. Responses due by 6/19/2006 (Attachments: # 1 Text of Proposed Order)(Relman, John) (Entered: 06/02/2006)

PAPERLESS ORDER granting 83 Motion for Extension of Time to File Response/Reply. Signed by Judge Benson Everett Legg on 06/02/2006. (Legg, Benson Everett) (Entered: 06/02/2006)

RESPONSE in Opposition re 78 MOTION for Partial Summary Judgment filed by Nancy Guzman. Replies due by 6/21/2006. (Lebau, Stephen) (Entered: 06/07/2006)

NOTICE by Nancy Guzman LENGHTY EXHIBITS (Lebau, Stephen) (Entered: 06/07/2006)

RESPONSE in Opposition re 78 MOTION for Partial Summary Judgment filed by Laura Thomas. Replies due by 6/21/2006. (Attachments: # 1 Table of Exhibits# 2 Exhibit A# 3 Exhibit B# 4 Exhibit C# 5 Exhibit D# 6 Exhibit E# 7 Exhibit F# 8 Exhibit G# 9 Exhibit I# 10 Exhibit J# 11 Errata K# 12 Exhibit L# 13 Exhibit M# 14 Exhibit N# 15 Exhibit O# 16 Exhibit P# 17 Exhibit Q# 18 Exhibit R# 19 Exhibit S# 20 Exhibit T# 21 Exhibit U# 22 Exhibit V# 23 Exhibit W)(Relman, John) (Entered: 06/07/2006)

NOTICE by Laura Thomas re 87 Response in Opposition to Motion,, of Filing of Lengthy Exhibit (Relman, John) (Entered: 06/07/2006)

RESPONSE in Opposition re 78 MOTION for Partial Summary Judgment filed by United States Equal Employment Opportunity Commission. Replies due by 6/21/2006. (Attachments: # 1 # 2 # 3 # 4 # 5 # 6 # 7 # 8 # 9)(Morocco, Maria) (Entered: 06/07/2006)

Consent MOTION for Extension of Time to File Response/Reply as to 89 Response in Opposition to Motion, 85 Response in Opposition to Motion, 87 Response in Opposition to Motion,, by Worthington, Moore &Jacobs, Inc.. Responses due by 7/14/2006 (Attachments: # 1 Text of Proposed Order)(Phelan, Jeanne) (Entered: 06/27/2006)

PAPERLESS ORDER granting 90 Motion for Extension of Time to File Response/Reply. Signed by Judge Benson Everett Legg on 06/28/2006. (Legg, Benson Everett) (Entered: 06/28/2006)

REPLY to Response to Motion re 78 MOTION for Partial Summary Judgment (Reply to Plaintiff EEOC Opposition to Motion) filed by Worthington, Moore &Jacobs, Inc.. (Attachments: # 1 Exhibit 29# 2 Exhibit 30)(Phelan, Jeanne) (Entered: 06/29/2006)

Consent MOTION for Extension of Time to File Response/Reply as to 85 Response in Opposition to Motion, 87 Response in Opposition to Motion,, by Worthington, Moore &Jacobs, Inc.. Responses due by 7/24/2006 (Attachments: # 1 Text of Proposed Order)(Phelan, Jeanne) (Entered: 07/07/2006)

REPLY to Response to Motion re 78 MOTION for Partial Summary Judgment (Reply to Opposition of Intervenor Plaintiffs) filed by Worthington, Moore &Jacobs, Inc.. (Attachments: # 1 Notice of Filing Lengthy Exhibits)(Phelan, Jeanne) (Entered: 07/11/2006)

PAPERLESS ORDER granting 93 Motion for Extension of Time to File Response/Reply. Signed by Judge Benson Everett Legg on 07/14/2006. (Legg, Benson Everett) (Entered: 07/14/2006)

MOTION for Leave to File Sur−Reply in Opposition to Defendant's Motion for Partial Summary Judgment by Laura Thomas. Responses due by 8/14/2006 (Attachments: # 1 Text of Proposed Order # 2 Intervenor Thomas'

PAPERLESS ORDER granting 96 Motion for Leave to File. Signed by Judge Benson Everett Legg on 08/15/2006. (Legg, Benson Everett) (Entered: 08/15/2006)

PAPERLESS ORDER granting 97 defendant's response. Briefing on the motion for summary judgment is closed. Signed by Judge Benson Everett Legg on 08/15/2006. (Legg, Benson Everett) (Entered: 08/15/2006)

Intervenor Laura Thomas' SURREPLY to Defendant's Reply to Intervenor Laura Thomas' Opposition to Defendant's Motion for Partial Summary Judgment, filed by Laura Thomas. (mcb, Deputy Clerk) Modified on 8/17/2006 (mcb, Deputy Clerk). (Entered: 08/17/2006)

REPLY to 100 Intervenor Thomas's SURREPLY, filed by Worthington, Moore &Jacobs, Inc. (mcb, Deputy Clerk) (Entered: 08/17/2006)

ORDER DIRECTING Counsel to submit paper copies of Docket Entry No. 78, 85 and 86, 87 and 92 to Chambers no later than February 27, 2007. Signed by Judge Benson Everett Legg on 2/23/07. (mcb, Deputy Clerk) (Entered: 02/23/2007)