Case: EEOC v. U-HAUL CO

EEOC v. U-Haul Intl Inc, et al

Equal Employment Opportunity Commission v. U-Haul International Inc and U-Haul of Illinois, Inc. d/b/a U-Haul Company of Northwest Chicago Suburbs

Carly Knight, Frank Dobbin, Alexandra Kalev

COMPLAINT; jury demand - Civil cover sheet - Appearance(s) of John C. Hendrickson, Diane Ilene Smason, Jeanne B. Szromba as attorney(s) for plaintiff (no summons(es) issued.) (Documents: (1-1 through 1-3)) (gma) (Entered: 09/22/2004)

WAIVER of service of summons as to defendant U-Haul Intl Inc sent on 9/22/04. (gma) (Entered: 10/26/2004)

WAIVER of service of summons as to defendant U-Haul of IL Inc sent on 10/21/04. (jmm) (Entered: 11/19/2004)

MINUTE ORDER of 11/5/04 by Hon. Joan Humphrey Lefkow: Status hearing is set for scheduling conference on 11/30/04 at 9:30 a.m. (Entered Order Setting Scheduling Conference.) Mailed notice by judge's staff. (gma) (Entered: 11/08/2004)

ATTORNEY APPEARANCE for defendants by D. Scott Watson, Gary R. Clark, Ellen Marie Girard (rbf) (Entered: 11/18/2004)

CORPORATE DISCLOSURE STATEMENT by defendant U-Haul Intl Inc (rbf) (Entered: 11/18/2004)

CORPORATE DISCLOSURE STATEMENT by defendant U-Haul of IL Inc; Notice. (rbf) (Entered: 11/18/2004)

MOTION by defendant U-Haul International Inc to dismiss for failure to state a claim (Attachments); Notice. (gma) (Entered: 12/01/2004)

ANSWER by defendant U-Haul International Inc and affirmative defenses to complaint [1-1]; Notice. (gma) (Entered: 12/01/2004)

MINUTE ORDER of 11/30/04 by Hon. Joan Humphrey Lefkow: Status hearing held. Response to defendant's motion to dismiss for failure to state a claim [8-1] is to be filed and served by 12/16/04; reply by 1/5/05; ruling will issue by mail. Amendments to the pleadings and/or joinder of additional parties may be sought upon appropriate motion by 1/14/05. All discovery will close on 4/29/05. The cut-off date for designation of plaintiff's trial expert is 5/31/05; for defendant's trial expert is 6/20/05. Motion(s) for summary judgment are to be filed by 8/1/05. Case shall be ready for trial by 1/3/06. Joint final pretrial order is to be filed by 12/1/05; plaintiff's complete draft shall be served on defendant by 11/15/05. (Entered Scheduling Order.) Mailed notice by judge's staff. (gma) (Entered: 12/01/2004)

RESPONSE by plaintiff EEOC to defendant U-Haul International, Inc.'s motion to dismiss for failure to state a claim [8-1] (Attachments). (gma) (Entered: 12/17/2004)

REPLY by defendant U-Haul Intl Inc to EEOC's motion to dismiss for failure to state a claim [8-1]; Notice. (rbf) (Entered: 01/06/2005)

JOINT MOTION by Plaintiff Equal Employment Opportunity Commission to extend discovery deadline (gma, ) (Entered: 04/11/2005)

NOTICE of Motion by U-Haul of Illinois, Inc. for presentment of JOINT MOTION by Plaintiff Equal Employment Opportunity Commission to extend discovery deadline 13 before Honorable Charles P. Kocoras on 4/18/2005 at 09:30 AM. (gma, ) (Entered: 04/11/2005)

MINUTE entry before Judge Charles P. Kocoras : Joint motion for extension of discovery deadline 13 is granted. Discovery ordered closed by 6/29/2005. Jury Trial is set on the joint trial calendar on 1/9/2006 at 10:00 AM. Judicial staff mailed notice (mad, ) (Entered: 04/19/2005)

AGREED MOTION by Defendant U-Haul of Illinois, Inc. to extend deadlines(gma, ) (Entered: 06/22/2005)

NOTICE of Motion by U-Haul of Illinois, Inc. for presentment of AGREED MOTION by Defendant U-Haul of Illinois, Inc. to extend deadlines 16 before Honorable Charles P. Kocoras on 6/28/2005 at 09:30 AM. (gma, ) (Entered: 06/22/2005)

MINUTE entry before Judge Charles P. Kocoras : Defendant's agreed motion to extend deadlines 16 is granted. Discovery deadline is extended to 8/25/2005. Date of 8/1/05 by which to file motion for summary judgment is vacated and may be reset at the next status hearing. Status hearing is set for 8/25/2005 at 09:30 AM. The case remains set on the January 2006 Joint Trial Calendar. Judicial staff mailed notice (mad, ) (Entered: 06/28/2005)

MINUTE entry before Judge Joan H. Lefkow : Status hearing of 8/25/05 is reset to 8/30/05 at 9:30 a.m. Defendant's motion to dismiss 8 is denied for the reasons stated below. Judicial staff mailed notice (mjc, ) (Entered: 08/11/2005)

JOINT MOTION by parties for extension of time to complete discovery (las, ) . (Entered: 08/16/2005)

NOTICE of Motion by D. Scott Watson for presentment of parties joint motion for extension of time to complete discovery 20 before Honorable Joan H. Lefkow on 8/18/2005 at 09:30 AM. (las, ) (Entered: 08/16/2005)

MINUTE entry before Judge Charles P. Kocoras : Joint motion for extension of time to 8/26/05 to complete discovery 20 is granted. Discovery ordered closed by 8/26/2005. Telephoned notice (mad, ) (Entered: 08/18/2005)

ANSWER by defendant U-Haul International, Inc. to complaint and affirmative defenses; Notice. (mjc, ) (Entered: 08/24/2005)

MINUTE entry before Judge Charles P. Kocoras : Status hearing held and continued to 10/6/2005 at 09:30 AM. In court notice (mad, ) (Entered: 08/30/2005)

MOTION by Defendants U-Haul International, Inc., U-Haul of Illinois, Inc. to withdraw appearances. (vcf, ) (Entered: 10/03/2005)

NOTICE of Motion by U-Haul International, Inc., U-Haul of Illinois, Inc. for presentment of motion to withdraw appearances 25 before Honorable Joan H. Lefkow on 10/6/2005 at 09:30 AM. (vcf, ) (Entered: 10/03/2005)

MOTION by Defendants U-Haul International, Inc., U-Haul of Illinois, Inc. for leave to substitute appearances (Cribaro-Mello, Camille) Modified on 10/4/2005 (ntf, ). (Entered: 10/03/2005)

NOTICE of Motion by Camille A. Cribaro-Mello for presentment of motion to substitute attorney 27 before Honorable Joan H. Lefkow on 10/6/2005 at 09:30 AM. (Cribaro-Mello, Camille) (Entered: 10/03/2005)

MINUTE entry before Judge Joan H. Lefkow : Status hearing held and continued to 11/10/2005 at 09:30 a.m. Defendants' motion to withdraw appearances 25 is granted. D. Scott Watson, Gary R. Clark and Ellen M. Girard of Quarles and Brady are given leave to withdraw as counsel for defendants. Defendants' motion for leave to substitute appearances 27 is granted. Manuel Sanchez, John S. Huntley and Camille Cribaro-Mello of Sanchez, Daniels & Hoffman are given leave to substitute their appearances on behalf of defendants. Defendants' oral motion for parties to supplement Rule 26 disclosures by 10/20/05 is granted. Attorney Manuel Sanchez for U-Haul International, Inc. and U-Haul of Illinois, Inc., John Scott Huntley for U-Haul International, Inc. and U-Haul of Illinois, Inc., Camille A. Cribaro-Mello for U-Haul International, Inc. and U-Haul of Illinois, Inc. added. Attorney D. Scott Watson; Gary R. Clark and Ellen Marie Girard terminated. Mailed notice (mjc, ) (Entered: 10/11/2005)

Subpoena for records by U-Haul International, Inc., U-Haul of Illinois, Inc. (Cribaro-Mello, Camille) (Entered: 10/10/2005)

ATTORNEY Appearance for Defendants U-Haul International, Inc., U-Haul of Illinois, Inc. by Camille A. Cribaro-Mello Appearances by Manuel Sanchez and John S. Huntley (Cribaro-Mello, Camille) (Entered: 10/11/2005)

ATTORNEY Appearance for Defendants U-Haul International, Inc., U-Haul of Illinois, Inc. by John Scott Huntley (Huntley, John) (Entered: 10/13/2005)

ATTORNEY Appearance for Defendants U-Haul International, Inc., U-Haul of Illinois, Inc. by Camille A. Cribaro-Mello (Cribaro-Mello, Camille) (Entered: 10/13/2005)

ATTORNEY Appearance for Defendants U-Haul International, Inc., U-Haul of Illinois, Inc. by Manuel Sanchez (Sanchez, Manuel) (Entered: 10/14/2005)

AMENDED by U-Haul International, Inc., U-Haul of Illinois, Inc. Defendant's Amended Rule 26(a)(1) Disclosures (Cribaro-Mello, Camille) (Entered: 10/20/2005)

NOTICE by U-Haul International, Inc., U-Haul of Illinois, Inc. Notice of Filing of Defendant's Amended Rule 26(a)(1) Disclosures (Cribaro-Mello, Camille) (Entered: 10/20/2005)

MOTION by Plaintiff Equal Employment Opportunity Commission, Defendants U-Haul International, Inc., U-Haul of Illinois, Inc. for extension of time Joint Motion to Extend Case Deadlines (Cribaro-Mello, Camille) (Entered: 10/26/2005)

Joint Motion to Extend Case Deadlines NOTICE of Motion by Camille A. Cribaro-Mello for presentment of motion for extension of time 37 before Honorable Joan H. Lefkow on 11/1/2005 at 09:30 AM. (Cribaro-Mello, Camille) (Entered: 10/26/2005)

MINUTE entry before Judge Joan H. Lefkow : Motion hearing held. Joint motion to extend case deadlines 37] is denied. Pretrial Order due date is extended to 12/15/2005. Settlement Conference is set for 12/6/2005 at 02:00 PM. Mailed notice (mad, ) (Entered: 11/02/2005)

MINUTE entry before Judge Joan H. Lefkow : Settlement conference held on 12/6/2005. Date by which to file pretrial order is extended to 12/20/2005. Pretrial conference is set for 12/21/2005 at 03:30 PM. In court notice (mad, ) (Entered: 12/07/2005)

MINUTE entry before Judge Matthew F. Kennelly : This case has been placed on the joint trial call that will begin on 1/9/06. Cases on that call will proceed on a "trailing" calendar to be tried as reached. The judges contributing cases are Judges Bucklo, Coar, Gettleman, Kennelly, and Lefkow. Any case may be assigned to any of the contributing judges. By 12/7/04, a list of cases will be available by link to the web pages of each of the judges participating. You can estimate the date on which your case will be called for trial by its location on the list, as ordinarily the cases will be called in the listed order, and no trial should last more than 5 days. As cases settle and trials are completed, the list will be updated. It will be necessary for all attorneys and parties to keep themselves and their witnesses ready for trial on no more than 48 hours notice. Mailed notice (or, ) (Entered: 12/09/2005)

PROPOSED Pretrial Order and Notice of Filing by Equal Employment Opportunity Commission (Szromba, Jeanne) (Entered: 12/20/2005)

MINUTE entry before Judge Joan H. Lefkow : Final pretrial conference held on 12/21/2005. (mad, ) (Entered: 12/21/2005)

MOTION by Plaintiff Equal Employment Opportunity Commission in limine to exclude evidence of absence of discrimination (Smason, Diane) Text modifed by Clerk's Office on 12/23/2005 (ntf, ). (Entered: 12/22/2005)

NOTICE by Equal Employment Opportunity Commission Notice of Filing Motion in Limine to Exclude Evidence of Absence of Discrimination (Smason, Diane) (Entered: 12/22/2005)

MOTION by Plaintiff Equal Employment Opportunity Commission in limine Motion in Limine to Exclude Evidence of Townes' Job Performance Unrelated to Employment Decisions at Issue (Smason, Diane) Text edited by Clerk's Office on 12/23/2005 (ntf, ). (Entered: 12/22/2005)

NOTICE by Equal Employment Opportunity Commission Notice of Filing Motion in Limine to Exclude Evidence of Townes' Job Performance (Smason, Diane) (Entered: 12/22/2005)

MOTION by Plaintiff Equal Employment Opportunity Commission in limine Motion in Limine to Exclude Testimony of EEOC Investigator (Smason, Diane) (Entered: 12/22/2005)

NOTICE by Equal Employment Opportunity Commission Notice of Filing Motion in Limine to Exclude Testimony of EEOC Investigator (Smason, Diane) (Entered: 12/22/2005)

MOTION by Defendants U-Haul International, Inc., U-Haul of Illinois, Inc. in limine Motion in Limine to Exclude Newspaper Articles, Motion in Limine to Exclude the Use of Deposition Testimony, Motion in Limine to Exclude Statements to the Media and Motion in Limine to Exclude Time-Barred Acts (Cribaro-Mello, Camille) (Entered: 12/27/2005)

NOTICE by U-Haul International, Inc., U-Haul of Illinois, Inc. Notice of Filing of Motions in Limine (Cribaro-Mello, Camille) (Entered: 12/27/2005)

AMENDED proposed pretrial order 42 by Equal Employment Opportunity Commission - adding Amended Special Verdict Form (Szromba, Jeanne) (Entered: 12/28/2005)

RESPONSE by Plaintiff Equal Employment Opportunity Commission to Defendants' Motion in Limine to Exclude Time-Barred Acts and Notice of Filing (Szromba, Jeanne) (Entered: 01/03/2006)

RESPONSE Plaintiff EEOC's Response to Defendants' Motion in Limine to Exclude the Use of Deposition Testimony and Notice of Filing (Smason, Diane) (Entered: 01/03/2006)

RESPONSE Plaintiff EEOC's Response to Defendants' Motion in Limine to Exclude Newspaper Articles and Notice of Filing (Smason, Diane) (Entered: 01/03/2006)

RESPONSE Plaintiff EEOC's Response to Defendants' Motion in Limine to Exclude Statements to the Media and Notice of Filing (Smason, Diane) (Entered: 01/03/2006)

RESPONSE Defendants Response to Plaintiff's Motion in Limine Regarding Evidence of Townes' Job Performance (Cribaro-Mello, Camille) (Entered: 01/03/2006)

NOTICE by U-Haul International, Inc., U-Haul of Illinois, Inc. Notice of Filing of Defendants Response to Plaintiff's Motion in Limine Regarding Evidence of Townes' Job Performance (Cribaro-Mello, Camille) (Entered: 01/03/2006)

RESPONSE Defendants' Response to Plaintiff's Motion in Limine to Exclude Testimony of EEOC Investigator (Cribaro-Mello, Camille) (Entered: 01/03/2006)

NOTICE by U-Haul International, Inc., U-Haul of Illinois, Inc. Notice of Filing of Defendants' Response to Plaintiff's Motion in Limine to Exclude Testimony of EEOC Investigator (Cribaro-Mello, Camille) (Entered: 01/03/2006)

RESPONSE Defendants' Response to Plalintiff's Motion in Limine to Exclude Evidence of Absence of Discrimination (Cribaro-Mello, Camille) (Entered: 01/03/2006)

NOTICE by U-Haul International, Inc., U-Haul of Illinois, Inc. Notice of Filing of Defendants' Response to Plaintiff's Motion in Limine to Exclude Evidence of Absence of Discrimination (Cribaro-Mello, Camille) (Entered: 01/03/2006)

PROPOSED Jury Instructions by U-Haul International, Inc., U-Haul of Illinois, Inc. (Cribaro-Mello, Camille) (Entered: 01/03/2006)

NOTICE by U-Haul International, Inc., U-Haul of Illinois, Inc. Notice of Filing of Defendants' Amended Pattern Instruction on Retaliation, Amended Special Verdict Form and Additional Pattern Cautionary Instruction on Reasonableness of Defendants' Action (Cribaro-Mello, Camille) (Entered: 01/03/2006)

MINUTE entry before Judge Joan H. Lefkow : Jury Trial reset to 1/10/2006 at 10:00 AM. Telephoned notice (mad, ) (Entered: 01/06/2006)

MINUTE entry before Judge Joan H. Lefkow : Plaintiff's first motion in lime 48 is denied without prejudice. Plaintiff's second motion in limine 46 is denied without prejudice. Plaintiff's third motion in limine 44 is granted as stated below. Defendants' first motion in limine 50 is granted as stated below. Defendants' second motion in limine 50 is granted without objection. Defendants' third motion in limine 50 is granted as stated below. Defendants' fourth motion in limine 50 is granted in part and denied in part. (mjc, ) (Entered: 01/09/2006)

Plaintiff's Proposed Amended Jury Instruction on Retaliation, Notice of Filing and Certificate of Service by Equal Employment Opportunity Commission (Smason, Diane) (Entered: 01/09/2006)

Exhibit List Defendant's Revised Trial Exhibit List by U-Haul International, Inc., U-Haul of Illinois, Inc.. (Cribaro-Mello, Camille) (Entered: 01/09/2006)

Plaintiff's Proposed Second Amended Special Verdict Form, Notice of Filing and Certificate of Service by Equal Employment Opportunity Commission (Smason, Diane) (Entered: 01/09/2006)

NOTICE by U-Haul International, Inc., U-Haul of Illinois, Inc. Notice of Filing of Defendant's Revised Trial Exhibit List (Cribaro-Mello, Camille) (Entered: 01/09/2006)

Plaintiff's Amended List of Exhibits, Notice of Filing and Certificate of Service by Equal Employment Opportunity Commission (Smason, Diane) (Entered: 01/09/2006)

ATTORNEY Appearance for Plaintiff Equal Employment Opportunity Commission by Diane Ilene Smason Appearance of Jean Kamp (Attachments: # 1 Notice of Filing Notice of Filing and Certificate of Service)(Smason, Diane) (Entered: 01/09/2006)

2 Notice of Filing Notice of Filing and Certificate of Service

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MINUTE entry before Judge Joan H. Lefkow : Jury trial begins. Trial held and continued to 1/11/2006 at 10:00 AM. In court notice (mad, ) (Entered: 01/11/2006)

MINUTE entry before Judge Joan H. Lefkow : Jury trial held and continued to 1/12/2006 at 09:45 AM. In court notice (mad, ) (Entered: 01/11/2006)

MINUTE entry before Judge Joan H. Lefkow : Jury trial held and continued to 1/13/2006 at 09:30 AM. In court notice (mad, ) (Entered: 01/13/2006)

MOTION by Defendants for judgment as a matter of law. (lcw, ) (Entered: 01/18/2006)

Verdict Form as to defendat U-Haul of Illinois only. (mjc, ) (Entered: 01/19/2006)

MINUTE entry before Judge Joan H. Lefkow : Jury trial held. Defendants' motion for judgment as a matter of law 76 is denied without prejudice. Jury deliberation held. Jury trial ends. Jury returns a verdict that as to both defendants U-Haul International, Inc. and U-Haul of ILlinois, plaintiff has not proven that Gary Townes' complaints of race discrimination were a motivating factor for the decision to demote him and plaintiff has not proven that Gary Townes' complaints of race discrimination were a motivating factor for the decision to terminate his employment. Judgment entered in favor of defendants and against plaintiff. Civil case terminated. (mjc, ) (Entered: 01/19/2006)

JUROR Note.(mjc, ) (Entered: 01/19/2006)

JURY Instructions.(mjc, ) (Entered: 01/19/2006)

ENTERED JUDGMENT. (mjc, ) (Entered: 01/19/2006)

TRANSCRIPT of proceedings for the following dates: 1/13/06; Before the Honorable Joan H. Lefkow. (mjc, ) (Entered: 07/17/2006)

EXCERPT OF TRANSCRIPT of proceedings for the following dates: 1/10/06, 1/11/06, 1/11/06,1/12/06; Before the Honorable Joan H. Lefkow. (4 vols.) (83-1 thru 83-4) (mjc, ) (Entered: 08/09/2006)