Evans v. Mitsubishi Motors

Aeschleman v. Mitsubishi Motor Mfg

No Court

U. S. Court of Appeals for the Seventh Circuit

102 F.3d 869

960 F.Supp. 164

990 F.Supp. 1059

No Court

Nancy Levit

COMPLAINT case referred to Mag. Judge Robert J. Kauffman - Certificate of Interest/Rule 41/Waiver of Service/Consent to Magistrate forms given to Plaintiff by Clerk (SH, ilcd) (SW, ilcd). (Entered: 04/09/1996)

ATTORNEY APPEARANCE for plaintiff EEOC (SH, ilcd) (Entered: 04/09/1996)

MOTION by plaintiff EEOC to transfer case from Judge McDade to Judge Mihm (VB, ilcd) (Entered: 06/20/1996)

CERTIFICATE OF INTEREST pursuant to Local Rule 11.3 filed by defendant Mitsubishi Motor Mfg (HK, ilcd) (Entered: 06/24/1996)

AFFIRMATIVE DEFENSES filed by defendant Mitsubishi Motor Mfg (HK, ilcd) (Entered: 06/24/1996)

RESPONSE by defendant Mitsubishi Motor Mfg to motion to transfer case from Judge McDade to Judge Mihm [3-1] (SH, ilcd) (Entered: 06/28/1996)

ORDER by Judge Joe B. McDade denying motion to transfer case from Judge McDade to Judge Mihm [3-1]. Case set for Initial Pre-Trial/ Rule 16 conference on Friday, 8/16/96 at 9:30am in person in Judge McDade's courtroom at the Federal Building in Peoria, IL. Rule 16 notice enclosed. Parties are to comply with Rule 26(f) by the time of the Rule 16 hearing and bring a proposed order as required by rule 16(b). FURTHER ORDERED that a Joint Hearing for Coordination of Discovery in this case and in 94-1545 (Evans vs Mitsubishi) is set on Friday, 9/6/96 at 3:00pm in person in Chief Judge Mihm's courtroom at the Federal Building in Peoria, IL. Attorneys from both cases are to be present at the 9/6/96 hearing. (cc: all counsel in cases 96-1192 & 94-1545) (HK, ilcd) (Entered: 07/08/1996)

NOTICE by defendant Mitsubishi Motor Mfg of change of address of Attorney Roy Davis (HK, ilcd) (Entered: 07/10/1996)

ATTORNEY APPEARANCE for plaintiff EEOC by Steven J Levine and Jean P Kamp (SH, ilcd) (Entered: 08/16/1996)

PROPOSED DISCOVERY PLAN filed by plaintiff, defendant (SH, ilcd) (Entered: 09/25/1996)

PROPOSED JOINT DISCOVERY/SCHEDULING PLAN filed by plaintiff & defendant (HK, ilcd) (Entered: 09/25/1996)

ORDER by Judge Joe B. McDade. Pursuant to Rule 16 Conference held 9/27/96 the Court enters the following scheduling order: joint agreed confidentiality protective order by 10/15/96; defts motion for confidentiality protective order (if necessary) by 10/25/96; phase I discovery to be completed by 2/1/97; dispositive threshold motions by 4/1/97 misc ddl of 6/15/97 created for amendment to pleadings; submission of pretrial memoranda by 7/1/97; Special Pretrial Conference set on July 11, 1997 at 10:30am-in person; Pltfs expert designations by 8/1/97; defts expert designations by 9/1/97; phases 2,3 & 4 discovery by 10/1/97; pltfs expert reports by 10/1/97; depositions of pltfs experts by 11/1/97; defts expert reports by 11/1/97; depositions of defts experts by 12/1/97; any dispositive motions to be filed by 12/1/97; joint final pretrial order due by 2/2/98; Final Pretrial/ jury instruction conf set at 9:00am on 2/16/98-in person; jury trial set at 9:00am on 3/2/98-in person. In addition 1) the Court waives any limitation of maximum number of interrogatories & depositions 2)all motions for protective order to be filed in written form & will be addressed to Judge McDade 3)Court refers the discovery portion to Mag Judge Kauffman. Motions to reconsider his rulings may be filed with Judge McDade. Case referred to Mag Judge Kauffman. (cc: all counsel) (HK, ilcd) Modified on 12/04/1996 (Entered: 09/30/1996)

LETTER from Attorney Waldmeir to Clerk of Court dated 9/26/96 re:9/27/96 hearing w/joint discovery schedule attached (HK, ilcd) (Entered: 09/30/1996)

MOTION by defendant Mitsubishi Motor Mfg to Clarify the EEOC'S September 13, 1996 letter to all of Mitsubishi's Current and Former Female Associates (HK, ilcd) (Entered: 10/24/1996)

MEMORANDUM IN SUPPORT of motion to Clarify the EEOC'S September 13, 1996 letter to all of Mitsubishi's Current Former Female Associates [14-1] by defendant Mitsubishi Motor Mfg (HK, ilcd) (Entered: 10/24/1996)

UNOPPOSED MOTION by defendant Mitsubishi Motor Mfg to extend time to comply with the protective order provisions of the 9/30/96 scheduling order (HK, ilcd) (Entered: 10/25/1996)

ATTORNEY APPEARANCE for Peter Brandt on behalf of defendant Mitsubishi Motor Mfg (LR, ilcd) (Entered: 10/28/1996)

MEMORANDUM IN OPPOSITION motion to Clarify the EEOC'S September 13, 1996 letter to all of Mitsubishi's Current and Former Female Associates [14-1] by plaintiff EEOC (SH, ilcd) (Entered: 11/07/1996)

MOTION by defendant Mitsubishi Motor Mfg for entry of (partially-agreed confidentiality) protective order (SH, ilcd) (Entered: 11/07/1996)

MEMORANDUM IN SUPPORT of motion for entry of (partially-agreed confidentiality) protective order [19-1] by defendant Mitsubishi Motor Mfg (SH, ilcd) (Entered: 11/07/1996)

CERTIFICATE of Service (Re: #19 & 20) by defendant Mitsubishi Motor Mfg (SH, ilcd) (Entered: 11/07/1996)

MOTION by defendant Mitsubishi Motor Mfg to withdraw attorney Roy G Davis (HK, ilcd) (Entered: 11/07/1996)

ORDER by Judge Joe B. McDade granting in part and denying in part the motion to Clarify the EEOC'S September 13, 1996 letter to all of Mitsubishi's Current and Former Female Associates [14-1]. FURTHER ORDERED that within 7 days of the date of this Order, EEOC shall send out the corrective notice on EEOC letterhead to all current and former female associates of Mitsubishi. (SEE ORDER); deadline for EEOC to send out corrective notice is 11/25/96. FURTHER ORDERED that all future proposed nonprivileged communications between counsel for either side and the potential class members in this case shall be forwarded to opposing counsel for a period of ten (10) calendar days for review. If opposing counsel has any objections to the content or form of such communications, they shall file an objection with the Court within such time. No communications shall be distributed to potential class members before the ten-day time period expires without objection or, if objections are filed, before the Court rules on them. FURTHER ORDERED that plaintiff EEOC is barred from relying upon any information gathered from managerial employees of Mitsubishi as the direct result of the September 13, 1996 letter. FURTHER ORDERED that plaintiff EEOC is barred from using any second-hand information gathered as a result of the September 13, 1996 letter in order to seek out and persuade other employees to join the plaintiff class. (SEE ORDER) (cc: all counsel) (VB, ilcd) (Entered: 11/14/1996)

MOTION by plaintiff EEOC & Evans Plaintiffs for order to set uniform briefing schedule and for joint hearing on Mitsubishi's motion for protective order (HK, ilcd) (Entered: 11/18/1996)

NOTICE by defendant Mitsubishi Motor Mfg of taking deposition duces tecum of Scott Sommers on 11/20/96 (SH, ilcd) (Entered: 11/18/1996)

MOTION by plaintiff EEOC for reconsideration (HK, ilcd) (Entered: 11/20/1996)

ORDER by Judge Joe B. McDade granting in part & denying in part the motion for reconsideration [26-1]. The corrective notice, as revised, shall read: See Order. Notice shall be sent out on EEOC letterhead on or before 11/27/96. (cc: all counsel) (HK, ilcd) (Entered: 11/21/1996)

MOTION by plaintiff EEOC to stay pending appeal (original of fax copy filed 11/25/96) (VB, ilcd) (Entered: 11/26/1996)

MEMORANDUM IN SUPPORT of motion to stay pending appeal [28-1] by plaintiff EEOC (original of fax copy filed 11/25/96) (VB, ilcd) (Entered: 11/26/1996)

NOTICE of APPEAL by plaintiff EEOC from Dist. Court decision [30-1] (original of fax copy filed 11/25/96) (VB, ilcd) (Entered: 11/26/1996)

ORDER by Judge Joe B. McDade denying motion to stay pending appeal (original of fax copy filed 11/25/96) [28-1] . The corrective notice shall be sent out on November 27, 1996, as originally scheduled. (cc: all counsel by fax and mail) (VB, ilcd) (Entered: 11/27/1996)

Notification by USCA of Appellate Docket Number 96-3957 (SH, ilcd) (Entered: 12/02/1996)

RESPONSE by defendant Mitsubishi Motor Mfg to joint motion of Evans Pltfs & EEOC for order to set uniform briefing schedule [24-1] and motion hearing on Mitsubishi's motion for protective order [24-2] (HK, ilcd) (Entered: 12/04/1996)

ORDER from USCA - Ordered that the appeal is dismissed for lack of jurisdiction (SH, ilcd) (Entered: 12/06/1996)

Notification by USCA of Appellate Docket Number 96-3988 (SH, ilcd) (Entered: 12/09/1996)

MOTION by plaintiff to extend time in which to respond to defendant Mitsubishii's objections to the EEOC's Proposed Letter to Mitsubishi Employees and preliminary response to correct immediately certain flase statements made by Mitsubishi (SH, ilcd) (Entered: 12/09/1996)

JOINT MOTION by EVANS plaintiffs and EEOC to exceed page limitation in response to Mitsubishi's Motion for Protective Order (SH, ilcd) (Entered: 12/10/1996)

RESPONSE by plaintiff EEOC to motion for entry of (partially-agreed confidentiality) protective order [19-1] (filed as Joint Memorandum of the Evans Plaintiffs and EEOC on Contested Protective Order Issues) (SH, ilcd) (Entered: 12/11/1996)

MOTION by intervenor Peoria Journal Star to intervene by Peoria Journal Star and for leave to file response to motion for entry of amended confidentiality protective order (HK, ilcd) (Entered: 12/12/1996)

MEMORANDUM IN SUPPORT of motion to intervene by Peoria Journal Star [39-1] by intervenor Peoria Journal Star (HK, ilcd) (Entered: 12/12/1996)

MOTION by plaintiff EEOC for leave to file certificate of service to joint memorandum of the Evans Plaintiffs and EEOC on contested protective order issues and joint motion of Evans Plaintiffs and EEOC to file an oversize brief in response to Mitsubishi's motion for protective order (HK, ilcd) (Entered: 12/12/1996)

RESPONSE by intervenor Peoria Journal Star to motion for entry of (partially-agreed confidentiality) protective order [19-1] (HK, ilcd) Modified on 12/13/1996 (Entered: 12/13/1996)

CERTIFICATE by plaintiff EEOC regarding joint memorandum of the Evans/EEOC pltfs on Contested Protective Order Issues and joint motion of Evans/EEOC to file an oversized brief in response to Mitsubishi's motion for protective order (HK, ilcd) (Entered: 12/17/1996)

TRANSCRIPT of joint hearing ( w/94-1545) held 12/12/96 on proposed protective order filed (CL, ilcd) Modified on 03/11/1997 (Entered: 12/27/1996)

MEMORANDUM IN RESPONSE by plaintiff EEOC to defendant's objections to the EEOC's proposed letter to Mitsubishi employess (VB, ilcd) (Entered: 12/31/1996)

Memorandum in RESPONSE by plaintiff EEOC to Defendant's Objections to the EEOC's Proposed letter to Mitsubishi Employees - NOTE: This is a copy of the Memorandum filed on 12/31/96, but has Exhibit A attached, which was not attached to the filing on 12/31/96. (SH, ilcd) (Entered: 01/07/1997)

MANDATE from USCA dismissing the appeal [30-1] - 96-3988 is DISMISSED as duplicative of appeal no. 96-3957 (SH, ilcd) Modified on 03/14/1997 (Entered: 01/28/1997)

MANDATE from USCA - motion for stay was denied, and the appeal dismissed [30-1], with costs, for want of jurisdiction (SH, ilcd) Modified on 03/14/1997 (Entered: 02/11/1997)

PROTECTIVE ORDER by Judge Joe B. McDade : SEE ORDER (original filed in Case No. 94-1545). (cc: all counsel) (LR, ilcd) Modified on 02/12/1997 (Entered: 02/12/1997)

NOTICE by plaintiff EEOC of change of Fax Number (new Fax Number is 312-353-8555 (SH, ilcd) (Entered: 02/18/1997)

Defendant Mitsubishi Motor Manufacturing of America, Inc's Objections to the EEOC's Third Proposed Letter to Mitsibishi Employees and MOTION by defendant Mitsubishi Motor Mfg for order to Enforce Scheduling Order (SH, ilcd) (Entered: 02/18/1997)

RESPONSE by plaintiff EEOC to Defendant's Objections to EEOC's Third Proposed Letter to Mitsubishi Employees and Motion to Enforce Scheduling Order [51-1] (SH, ilcd) (Entered: 03/03/1997)

MOTION by plaintiff EEOC, defendant Mitsubishi Motor Mfg for order (filed as Stipulation for Temporary Suspension of Case) (SH, ilcd) (Entered: 03/12/1997)

ORDER by Judge Joe B. McDade granting motion for order (filed as Stipulation for Temporary Suspension of Case) [53-1]. This matter shall be placed in temporary suspense until 3/20/97. (cc: all counsel) (SH, ilcd) (Entered: 03/14/1997)

MOTION by defendant Mitsubishi Motor Mfg for leave to file reply memorandum in support of its objections to the EEOC's 3rd Proposed Letter to Mitsubishi Employees & Motion to Enforce Scheduling Order (HK, ilcd) (Entered: 03/20/1997)

ORDER by Judge Joe B. McDade granting in part and denying in part motion for order to Enforce Scheduling Order [51-1]. EEOC's 3rd proposed letter may be sent out immediately with the following redactions: (1) the phrase "observed or" in the first sentence of paragraph two; (2) the phrase "or who witnessed" in the second sentence of paragraph two; (3) the phrase "or to other employees" in the last sentence of paragraph three; and (4) paragraphs four and six in their entirety. FURTHER ORDERED that EEOC shall turn over its list of alleged victims to Mitsubishi within 5 days of the date it sends out the letter discussed above. FURTHER ORDERED that any future attempt by Mitsubishi to engage in discussions with alleged victims concerning past incidents of harassment must be done by a noticed deposition in accordance with the Federal Rules of Civil Procedure. FURTHER ORDERED that the parties shall prioritize and depose as soon as practicable any alleged victim who has information about ongoing harassment at Mitsubishi's Normal, IL plant. Likewise, the parties shall expedite those depositions which Mitubishi can justify by its need to investigate and remedy any previously unreported incidences of harassment. Specific disputes shall be taken up with Magistrate Kauffman. FURTHER granting motion for leave to file reply memorandum in support of its objections to the EEOC's 3rd Proposed Letter to Mitsubishi Employees & Motion to Enforce Scheduling Order [55-1] (cc: all counsel) (SH, ilcd) (Entered: 03/24/1997)

REPLY by defendant Mitsubishi Motor Mfg to response to motion for order to Enforce Scheduling Order [51-1] (filed as Defendant's Reply Memorandum in Support of its Objections to the EEOC's Third Proposed Letter to Mitsubishi Employees and Motion to Enforce Scheduling Order) (SH, ilcd) (Entered: 03/24/1997)

MOTION by plaintiff EEOC for reconsideration (FAX DOCUMENT) (SH, ilcd) (Entered: 03/28/1997)

MOTION by plaintiff EEOC for reconsideration (original of fax document #58) (SH, ilcd) (Entered: 03/31/1997)

MOTION by plaintiff, defendant for order to Modify Joint Discovery/Scheduling Plan (filed as Stipulation to Modify) (SH, ilcd) (Entered: 04/01/1997)

MOTION by defendant Mitsubishi Motor Mfg for leave to file response to the EEOC's Motion to Reconsider (original of fax documenet #61) (SH, ilcd) (Entered: 04/02/1997)

ORDER by Judge Joe B. McDade granting motion for order to Modify Joint Discovery/Scheduling Plan [60-1]. Ordered that the deadlines for Phase I Discovery and Dispositive Threshold Motions, except as otherwise ordered, shall be extended to 6/1/97. (cc: all counsel) (SH, ilcd) (Entered: 04/02/1997)

ORDER by Judge Joe B. McDade granting motion for reconsideration [59-1] [58-1]. The second paragraph is reworded to reflect EEOC's concern, as indicated in this order. Further ordered that Defendant's motion for leave to file response to the EEOC's Motion to Reconsider [61-1] is granted. (cc: all counsel) (SH, ilcd) (Entered: 04/02/1997)

RESPONSE by defendant Mitsubishi Motor Mfg to motion for reconsideration [59-1] (SH, ilcd) (Entered: 04/02/1997)

NOTICE by defendant Mitsubishi Motor Mfg of change of address of law firm of Miller, Canfield, Paddock and Stone (SH, ilcd) (Entered: 04/25/1997)

LETTER to court from defendant counsel requesting status conference (SH, ilcd) (Entered: 05/19/1997)

MOTION by plaintiff EEOC for order to disregard Deft Counsel's 5/7/97 letter to Judge McDade and to require Deft to communicate with the Court by motion (HK, ilcd) (Entered: 05/13/1997)

MEMORANDUM OF LAW IN SUPPORT of motion for order to disregard Deft Counsel's 5/7/97 letter to Judge McDade and to require Deft to communicate with the Court by motion [66-1] by EEOC (HK, ilcd) (Entered: 05/13/1997)

ATTORNEY APPEARANCE for plaintiff EEOC by Michelle A. Caiola as additional counsel (SH, ilcd) (Entered: 05/16/1997)

MOTION by defendant Mitsubishi Motor Mfg for reconsideration of minute entry granting plaintiff's motion to disregard defendant counsel's 5/7/97 letter to Judge McDade and to require counsel to communicate with the Court by motion and in the alternative, motion to regard defendant's 5/7/97 as a motion for a telephonic status conference (SH, ilcd) (Entered: 05/20/1997)

MEMORANDUM IN SUPPORT of motion for reconsideration of minute entry granting plaintiff's motion to disregard defendant counsel's 5/7/97 letter to Judge McDade and to require counsel to communicate with the Court by motion and in the alternative, motion to regard defendant's 5/7/97 as a motion for a telephonic status conference [70-1] by defendant Mitsubishi Motor Mfg (SH, ilcd) (Entered: 05/20/1997)

CERTIFICATE of Service re: #70 & #71 by defendant Mitsubishi Motor Mfg (SH, ilcd) (Entered: 05/20/1997)

MOTION by EEOC, Mitsubishi Motor Mfg for order to modify joint discovery/scheduling plan (filed as Stipulation to Modify) (SH, ilcd) (Entered: 06/02/1997)

ORDER by Judge Joe B. McDade Ordered that the deadlines for Phase I Discoverey and Dispositive Threshold Motions, except as otherwise ordered, shall be extended to 8/1/97. (cc: all counsel) (SH, ilcd) (Entered: 06/04/1997)

MOTION by defendant Mitsubishi Motor Mfg to exceed page limitation in support of its motion to dismiss and/or for partial summary judgment (SH, ilcd) Modified on 09/17/1997 (Entered: 07/23/1997)

MEMORANDUM IN SUPPORT of motion to exceed page limitation in support of its motion to dismiss and/or for partial summary judgment [75-1] by defendant Mitsubishi Motor Mfg (SH, ilcd) (Entered: 07/23/1997)

CERTIFICATE of Service re: #75 & 76 by defendant Mitsubishi Motor Mfg (SH, ilcd) (Entered: 07/23/1997)

MOTION by defendant Mitsubishi Motor Mfg for partial summary judgment (VB, ilcd) (Entered: 08/04/1997)

MEMORANDUM IN SUPPORT of motion for partial summary judgment [78-1] by defendant Mitsubishi Motor Mfg (VB, ilcd) (Entered: 08/04/1997)

MOTION by defendant Mitsubishi Motor Mfg for leave to file materials under seal in connection with its motion for partial summary judgment (VB, ilcd) (Entered: 08/04/1997)

MEMORANDUM IN SUPPORT of motion for leave to file materials under seal in connection with its motion for partial summary judgment [80-1] by defendant Mitsubishi Motor Mfg (VB, ilcd) (Entered: 08/04/1997)

STATEMENT OF FACTS ( undisputed) by defendant Mitsubishi Motor Mfg in support of motion for partial summary judgment [78-1] (VB, ilcd) (Entered: 08/04/1997)

EXHIBITS for defendant Mitsubishi Motor Mfg stored in file in support of defendant's memorandum in support of motion for partial summary judgment (VB, ilcd) (Entered: 08/04/1997)

EXHIBITS for defendant Mitsubishi Motor Mfg stored in file to affidavit of Paul Betts filed in support of defendant's memorandum of law in support of motion for partial summary judgment (VB, ilcd) (Entered: 08/04/1997)

STATEMENT OF THEORY OF CASE by defendant Mitsubishi Motor Mfg (VB, ilcd) (Entered: 08/04/1997)

IN CAMERA documents by defendant Mitsubishi Motor Mfg sealed and placed in vault in accordance with the Court's pretrial protective order dated 2/12/97 in support of motion for partial summary judgment (VB, ilcd) (Entered: 08/04/1997)

CERTIFICATE (PROOF OF SERVICE) by defendant Mitsubishi Motor Mfg re: documents #78-#85 (VB, ilcd) (Entered: 08/04/1997)

MOTION by plaintiff EEOC for order to set briefing schedule (SH, ilcd) (Entered: 08/11/1997)

RESPONSE by defendant Mitsubishi Motor Mfg to motion for order to set briefing schedule [88-1] (SH, ilcd) (Entered: 08/11/1997)

Joint MOTION by plaintiff, defendant to reset status conference (SH, ilcd) (Entered: 08/11/1997)

ORDER by Judge Joe B. McDade granting motion for order to set briefing schedule [88-1]. Plaintiff's response to Defendant's motion for partial summary judgment [78-1] due 9/15/97; Defendant's reply due 10/2/97. No further threshold motions or briefs shall be filed without prior leave of this Court. Further, court is denying motion to reset status conference [90-1]. At this point, the hearing remains set for 9/18/97 at 9:30 AM in person in Peoria. However, at the request of the parties, the hearing may be delayed until after Defendant's motion for partial summary judgment has been resolved by the Court. (cc: all counsel) (SH, ilcd) (Entered: 08/14/1997)

ORDER by Judge Joe B. McDade - Upon further consideration, the Court is changing the 9:30 AM, Thurs., 9/19/97 hearing to a telephone status conference rather than requiring the parties to appear in person. The Court will set up the call. The parties should be prepared to discuss the present status of the case as well as any issues that may require the Court's intervention or guidance, such as discovery or other scheduling matters. However, because Defendant's motion for partial summary judgment will not be resolved by the time of the hearing, the Court will leave it to another day to schedule the special pretrial conference referenced in the Court's original scheduling order in this case. (cc: all counsel) (SH, ilcd) (Entered: 08/14/1997)

MOTION by plaintiff EEOC for leave to file first amended complaint (SH, ilcd) (Entered: 08/14/1997)

MOTION by plaintiff EEOC for protective order (SH, ilcd) (Entered: 08/20/1997)

Memorandum of Law in RESPONSE by defendant to motion for leave to file first amended complaint [93-1] (SH, ilcd) (Entered: 08/22/1997)

RESPONSE by defendant to motion for protective order [94-1] (SH, ilcd) (Entered: 08/22/1997)

ORDER by Judge Joe B. McDade granting in part motion for protective order [94-1] and suspends the taking of depositions in this case by either party until 9/18/97. All further discovery matters will be discussed at the telephone status hearing scheduled for 9/18/97, including EEOC's suggestion that depositions be limited to six per week until the partial summary judgment motion is resolved. Court is granting motion for leave to file materials under seal in connection with its motion for partial summary judgment [80-1]. Ruling on motion for leave to file first amended complaint [93-1] is deferred because that motion is apparently tied up with the merits of Defendant's partial summary judgment motion. (cc: all counsel) (SH, ilcd) Modified on 09/17/1997 (Entered: 08/25/1997)

MOTION by plaintiff EEOC for leave to file reply memorandum in support of motion of EEOC for leave to file First Amended Complaint (SH, ilcd) (Entered: 08/27/1997)

MOTION by plaintiff EEOC for leave to file, instanter, an overlength memorandum in opposition to defendant's motion for partial summary judgment (SH, ilcd) (Entered: 09/15/1997)

STATEMENT OF FACTS (disputed) by plaintiff EEOC in opposition to motion for partial summary judgment [78-1] (SH, ilcd) (Entered: 09/15/1997)