Case: EEOC v. KEY BANK NATIONAL ASSOCIATION

EEOC v. Keybank, N.A.

Carly Knight, Frank Dobbin, Alexandra Kalev

FILING FEE WAIVED (B,BA A) (Entered: 03/21/2000)

ASSIGNMENT OF MAGISTRATE JUDGE pursuant to Local Rule 3.1, Assignment of Cases. In the event of referral this case will be referred to Mag. Judge David S. Perelman . 1 pg (B,E J) (Entered: 03/21/2000)

COMPLAINT; jury demand ( Service: summons, magistrate consent form issd) ( 6 pgs) (B,E J) (Entered: 03/21/2000)

CIS filed by plaintiff. ECF Req. By Donna L. Williams-Alexander Recommended Track: standard ( 2 pgs) (B,E J) (Entered: 03/21/2000)

ANSWER to Complaint by deft. ( 4 pgs) (H,D) (Entered: 04/14/2000)

CIS filed by deft. ECF Req. By Sue Marie Douglas Recommended Track: Standard. ( 2 pgs) (H,D) (Entered: 04/14/2000)

CASE MANAGEMENT CONFERENCE scheduling order. case management conference set for 10:30 on 5/25/00 (issued on 4/26/00) ( 3 pgs) Judge Kathleen M. O'Malley [EOD Date: 4/27/00] (S,R) (Entered: 04/27/2000)

POSITION STATEMENT by parties Re: Agenda for Case Management Conf. ( 3 pgs) (E,P) (Entered: 05/22/2000)

CASE MANAGMENT PLAN/ORDER: Track Designation: standard ; case management conference held 5/25/00 ;Ct refers this case to mediation to occur no later than 11/1/00; non-expert discovery ddl 11/17/00; expert reports exchanged by pltf 12/17/00 and dft 1/17/01; expert discovery ddl 2/17/01; pldgs amd and/or ptys added by 8/15/00; dispositive motion ddl 1/17/01; status hrg will be set upon receipt of report of the mediator (issued on 5/25/00) ( 4 pgs) Judge Kathleen M. O'Malley [EOD Date: 5/26/00] (S,R) (Entered: 05/26/2000)

NOTICE OF REFERRAL to MED. List of potential neutrals sent to parties. Neutral selection ddl set for 6/9/00; Process to be completed by 11/13/00; Hrg to be sched/hld by 11/1/00. (issd 5/30/00) (V,K) Modified on 06/13/2000 (Entered: 05/30/2000)

NOTICE of potential selection as neutral sent to first potential neutral. Neutral to respond by 6/16/00. (V,K) (Entered: 06/13/2000)

NOTICE received from first potential neutral re: conflict. Neutral Available (y/n): y. (V,K) (Entered: 06/16/2000)

NOTICE of parties selection of neutrals. Hrg to be set by 11/1/00; Process to be completed by 11/13/00; Designated neutral: Bruce G Hearey. (14 pgs) (V,K) (Entered: 06/16/2000)

NOTICE of ADR Administrator. Agreed ranking sheet rcvd from all cnsl. (ranking sheet was due 6/9/00) (3 pgs) (V,K) (Entered: 06/19/2000)

SUBPOENA returned. Served on Jose A. Quintana thru Angel Rolan on 6/20/00. ( 3 pgs) (M,J A A) (Entered: 06/22/2000)

EX PARTE STATUS Report by pltf. (1 pg) (V,K) (Entered: 07/10/2000)

MEDIATION HEARING set for 9:30 10/18/00 at office of mediator, 925 Euclid Ave., Suite 2000, Cleve, OH 44115-1496. Report due by 10/30/00 (S,J) (Entered: 08/07/2000)

AMENDED COMPLAINT by plaintiff EEOC; jury demand [1-1] (8 pgs) (S,R) (Entered: 08/16/2000)

SUBPOENA returned. Issued on behalf of deft. Served 9/18/00 on Carmen Colon. (2 pgs) (V,K) (Entered: 09/20/2000)

MOTION by mediator Bruce G. Heary for sanctions against pltf. w/Afdt in supp. ( 20 pgs) (D,P N.) (Entered: 10/30/2000)

NOTICE by deft of taking depo duces tecum of Luz Elvelyn Serrano on 11/9/00 ( 3 pgs) (E,P) Modified on 11/01/2000 (Entered: 11/01/2000)

SUBPOENA returned. Issued on behalf of KeyBank. Served on Evelyn Luz Serrano on 11/3/00. (2 pgs) (V,K) (Entered: 11/08/2000)

MEMORANDUM by pltf in opp to mot by mediator Bruce G. Heary for sanctions against pltf [14-1]. (12 pgs) (V,K) (Entered: 11/20/2000)

REPLY by mediator Bruce G Hearey to memo against mot by mediator Bruce G. Heary for sanctions against pltf [14-1]. (5 pgs) (V,K) (Entered: 11/28/2000)

MEDIATION REPORT. Med. Hrg held Disp: 8. Future ADR: None. (D,P N.) (Entered: 02/01/2001)

SUR-REPLY memo by pltf re [14-1] motion by mediator Bruce G. Heary for sanctions against pltf. ( 7 pgs) (V,K) (Entered: 12/05/2000)

NOTICE of hrg in room 135, before Hon. Kathleen M. O'Malley on mot by mediator Bruce G. Heary for sanctions against pltf [14-1] at 2:00 p.m. on 2/2/01. (issd 1/11/01) (1 pg) (V,K) (Entered: 01/12/2001)

MOTION by pltf in limine on the issue of presentation of matters irrelevant to the Mediator's recommendation for sanctions. ( 3 pgs) (H,D) (Entered: 02/02/2001)

MOTION by pltf in limine on the issue of privileged communications between attys. ( 3 pgs) (M,J A A) (Entered: 02/02/2001)

MINUTS/ORDER granting mot by mediator Bruce G. Heary for sanctions against pltf [14-1]. Mr. Hearey will submit an afdvt as to his costs on or before 2/16/01; EEOC may resp on or before 3/2/01. (issd 2/2/10) (1 pg) Judge Kathleen M. O'Malley [EOD Date: 2/5/01] (V,K) (Entered: 02/05/2001)

MOTION by pltf for reconsideration of ord granting Mediator's recommendation for sanctions (4 pgs) (V,K) (Entered: 02/13/2001)

AFFIDAVIT/SUBMISSION of Bruce G. Hearey of stmnt for services [23-2]. (8 pgs) (V,K) (Entered: 02/16/2001)

MARGINAL ENTRY ORDER denying mtn by pltf for reconsideration [24-1]; The memorandum mischaracterizes and/or misunderstands the basis for the courts order. The EEOC violated the courts order and the courts local rules, misrepresented counsels settlement authority and unduly increased the cost of addressing those matters. (issued on 3/8/01) Judge Kathleen M. O'Malley [EOD Date: 3/8/01] (M,J A A) (Entered: 03/08/2001)

ORDER: pursuant to Court's earlier order that pltf to pay $2,993.00 as a sanction for failure to comply with its obligations relating to a court-ordered mediation in this matter. Payment shall be made payable to Bruce G. Hearey, the mediator within 10 days of this order (issued on 3/23/01) ( 1 pgs) Judge Kathleen M. O'Malley [EOD Date: 3/26/01] (K,V) (Entered: 03/26/2001)

MOTION by pltf for a 30 day enlargement of time in which to pay the Mediator pursuant to court order ( 3 pgs) (M,EJ) (Entered: 04/04/2001)

MARGINAL ENTRY ORDER: granting motion by pltf for a 30 day enlargement of time in which to pay the Mediator pursuant to court order [27-1] (issued on 4/18/01) Judge Kathleen M. O'Malley [EOD Date: 4/18/01] (C,B) (Entered: 04/18/2001)

JOINT MOTION by ptys to appove & enter consent order & judgment entry ( 2 pgs) (H,D) (Entered: 05/10/2001)

CONSENT ORDER granting motion by ptys to appove & enter consent order & judgment entry; the term of this Decree shall be 1 yr from date of entry by the Ct; KeyBank shall pay a total of $24,000.00 to charging ptys; deft shall post ntc (Exh B) w/in 10 days for 1 yr in Cuyahoga Cty's branches, etc; this Ct shall retain jurisdiction for purposes of insuring compliance; each pty shall bear its own costs; [28-1] dismissing case (issued on 5/8/01) ( 42 pgs) Judge Kathleen M. O'Malley [EOD Date: 5/10/01] (H,D) (Entered: 05/10/2001)

JUDGMENT entered dismissing all claims against deft w/prej; ptys to bear their own costs & fees, including attys' fees; the Ct retains jurisdiction during the duration of the consent order for the purpose of its enforcement. (issued on 5/8/01) ( 2 pgs) Judge Kathleen M. O'Malley [EOD Date: 5/10/01] (H,D) (Entered: 05/10/2001)