Case: EEOC v. GRAVES ENVIRONMENTAL & GEOTECHNICAL SERVICES, INC.

EEOC v. Graves Environmental

EEOC v. Graves Environmental and Geotechnical Services, Inc.

EEOC v. Graves Environmental and Geotechnical Services, Inc.

EEOC v. Graves Environmental and Geotechnical Services, Inc.

EEOC v. Graves Environmental and Geotechnical Services, Inc.

EEOC v. Graves Environmental and Geotechnical Services, Inc.

Carly Knight, Frank Dobbin, Alexandra Kalev

COMPLAINT; Scheduling order due by 5/12/00 Service due by 5/30/00 for Graves Environmental (kric) (Entered: 01/31/2000)

Answers to 16B Interrogatories by plaintiff EEOC; jury demand (kric) (Entered: 01/31/2000)

MOTION by plaintiff EEOC for Roderick Ventura to appear pro hac vice (ttil) (Entered: 02/28/2000)

AFFIDAVIT of Roderick Ventura by plaintiff EEOC Re: [3-1] motion for Roderick Ventura to appear pro hac vice (ttil) (Entered: 02/28/2000)

MOTION to intervene by Bette J Kane and to join James K. Branch as a defendant (ttil) (Entered: 03/21/2000)

MEMORANDUM by movant Bette J Kane in support of [6-1] motion to intervene by Bette J Kane (ttil) (Entered: 03/21/2000)

ANSWER to Local Rule 26.03 Interrogatories by movant Bette J Kane (ttil) (Entered: 03/21/2000)

RESPONSE by defendant Graves Environmental in opposition to [6-1] motion to intervene by Bette J Kane (former empl) (Entered: 04/06/2000)

ANSWER to Complaint by defendant Graves Environmental (Attorney Sue C Erwin) (former empl) (Entered: 04/06/2000)

REPLY by plaintiff EEOC to memorandum in opposition to [6-1] motion to intervene by Bette J Kane (ttil) (Entered: 04/13/2000)

SCHEDULING ORDER setting Plaintiff's ID of Experts set for 9/25/00 ; Defendant's ID of Experts set for 9/25/00 ; Joining of parties,amending of pleadings on 8/24/00 ; Deadline for filing of all motions 1/24/01 ; Discovery cutoff 12/26/00 ; ( signed by Magistrate Judge Joseph R. McCrorey ) (ttil) (Entered: 07/28/2000)

MOTION with attached exhibits A&B by plaintiff EEOC to compel answer to request for production No. 16 (former empl) (Entered: 08/14/2000)

MEMORANDUM by plaintiff EEOC in support of [13-1] motion to compel answer to request for production No. 16 (former empl) (Entered: 08/14/2000)

MOTION by plaintiff EEOC for Roderick Ventura to withdraw as attorney (ttil) (Entered: 08/25/2000)

ORDER granting [15-1] motion for Roderick Ventura to withdraw as attorney (Terminated attorney Roderick Ventura for EEOC ( signed by Magistrate Judge Joseph R. McCrorey ) (ttil) (Entered: 08/29/2000)

DESIGNATION OF EXPERTS by plaintiff EEOC (ttil) (Entered: 09/27/2000)

ANSWER to Interrogatories by intervenor/plaintiff Bette J Kane (ttil) (Entered: 09/27/2000)

AMENDED MOTION by movant Bette J Kane to intervene and join James K. Branch and interrelated companies as defendants referring to [6-1] motion to intervene by Bette J Kane (ttil) (Entered: 11/13/2000)

OPPOSITION by defendant Graves Environmental to [6-1] motion to intervene by Bette J Kane (ttil) (Entered: 11/24/2000)

REPLY by movant Bette J Kane to memorandum in opposition to [19-1] amended motion to intervene and join James K. Branch and interrelated companies as defendants (ttil) (Entered: 11/30/2000)

CONSENT PROTECTIVE ORDER ( signed by Magistrate Judge Joseph R. McCrorey ) (ttil) (Entered: 12/06/2000)

ORDER granting [19-1] amended motion to join interrelated companies as defendants, granting in part, [6-1] motion to intervene by Bette J Kane and denying in part [6-1] motion to add James Branch as a defendant; intervenor/plaintiff Betty Kane's motion to add her ADEA claim is granted ( signed by Magistrate Judge Joseph R. McCrorey ) (ttil) (Entered: 12/06/2000)

OBJECTION by defendant Graves Environmental to [24-1] order (former empl) (Entered: 12/20/2000)

ANSWER by defendant Graves Environmental to intervenors amended complaint (intervenors amended complaint has not been filed) (ttil) (Entered: 12/22/2000)

MOTION and memorandum in support by defendant Graves Environmental for an independent physical and mental examination of Bette Kane pursuant to Rule 35 (ttil) (Entered: 01/09/2001)

REPLY by plaintiff EEOC to [25-1] objection (former empl) (Entered: 01/09/2001)

ORDER affirming USMJ McCrorey's 12/5/00 order and denying [25-1] objection/appeal ( signed by Judge Cameron M. Currie ) (former empl) (Entered: 01/10/2001)

Amended Answers to 16B Interrogatories by defendant Graves Environmental (ydav) (Entered: 01/18/2001)

RESPONSE by plaintiff EEOC to [27-1] motion for an independent physical and mental examination of Bette Kane pursuant to Rule 35 (cqui) (Entered: 01/23/2001)

MOTION by plaintiff EEOC for protective order (cqui) (Entered: 01/25/2001)

RESPONSE by intervenor-plaintiff Betty J Kane to [27-1] motion for an independent physical and mental examination of Bette Kane pursuant to Rule 35 (former empl) (Entered: 01/24/2001)

REPLY by defendant Graves Environmental to response to [27-1] motion for an independent physical and mental examination of Bette Kane pursuant to Rule 35 (ttil) (Entered: 02/02/2001)

MOTION by plaintiff EEOC for Kara L. Gibbon Haden to appear pro hac vice FILING FEE AMOUNT: fee waived (plaintiff is gov't agency) (ttil) (Entered: 02/26/2001)

AMENDED SCHEDULING ORDER setting Discovery cutoff 4/9/01 ; Deadline for filing of all motions 5/1/01 ; ( signed by Magistrate Judge Joseph R. McCrorey ) (ttil) (Entered: 03/19/2001)

SUPPLEMENTAL RESPONSES to Local Rule 26 Interrogatories by plaintiff EEOC (ttil) (Entered: 04/10/2001)

NOTICE of Hearing before Magistrate Judge Joseph R. McCrorey set Motion Hearing to 10:00 4/20/01 for [31-1] motion for protective order, to 10:00 4/20/01 for [27-1] motion for an independent physical and mental examination of Bette Kane pursuant to Rule 35 (ttil) (Entered: 04/10/2001)

NOTICE of Hearing before Magistrate Judge Joseph R. McCrorey reset Motion Hearing to 2:30 4/19/01 for [31-1] motion for protective order, to 2:30 4/19/01 for [27-1] motion for an independent physical and mental examination of Bette Kane pursuant to Rule 35 (ttil) (Entered: 04/11/2001)

MOTION HEARING [27-1] motion for an independent physical and mental examination of Bette Kane pursuant to Rule 35 held ORAL ORDER [27-1] motion for an independent physical and mental examination of Bette Kane pursuant to Rule 35 taken under advisement (before Magistrate Judge Joseph R. McCrorey ) Court Reporter: ESR/Tape01B20:894-2963. (ttil) (Entered: 04/20/2001)

ORDER denying [31-1] motion for protective order, granting [27-1] motion for an independent physical and mental examination of Bette Kane pursuant to Rule 35 ( signed by Magistrate Judge Joseph R. McCrorey ) mld (mdea) (Entered: 04/26/2001)

Copy of transcripts of videotaped DEPOSITION of Bette Kane, volumes I-III filed pursuant to Judge McCrorey's order of 4/25/01 (mdea) (Entered: 04/26/2001)

SECOND AMENDED SCHEDULING ORDER setting Discovery cutoff 5/24/01 ; Deadline for filing of all motions 6/25/01 ; Jury Selection deadline set for 7/2/01 ; ( signed by Magistrate Judge Joseph R. McCrorey ) eod/mld (mdea) (Entered: 04/26/2001)

MOTION by plaintiff EEOC for David R Treeter to withdraw as attorney and add attorney Edwin L. Turnage as attorney of record (ttil) (Entered: 05/17/2001)

NOTICE of attorney appearance for plaintiff EEOC by Edwin Lake Turnage (ttil) (Entered: 05/17/2001)

ORDER granting [44-1] motion for David R Treeter to withdraw as attorney and add attorney Edwin L. Turnage as attorney of record (Terminated attorney David R Treeter for EEOC ( signed by Magistrate Judge Joseph R. McCrorey ) (ttil) (Entered: 05/22/2001)

Intervenor/Plaintiff's ID of Experts by EEOC (former empl) (Entered: 05/30/2001)

Answers to 16B Interrogatories by defendant Graves Environmental (former empl) (Entered: 05/30/2001)

MOTION by defendant Graves Environmental for summary judgment (bbro) (Entered: 07/12/2001)

MEMORANDUM by defendant Graves Environmental in support of [50-1] motion for summary judgment with attachments 1-15 (bbro) (Entered: 07/12/2001)

MOTION by plaintiff EEOC for partial summary judgment (bbro) (Entered: 07/12/2001)

MEMORANDUM by plaintiff EEOC in support of [52-1] motion for partial summary judgment with Exhibits A and B and other attachments (bbro) (Entered: 07/12/2001)

MOTION with memorandum in support by movant Bette J Kane for summary judgment (bbro) (Entered: 07/12/2001)

AFFIDAVIT of Kenneth W Jacobsen by defendant Graves Environmental (cqui) (Entered: 07/13/2001)

ORDER extending time to respond to each other's summary judgment motions , Response to motion reset to 8/1/01 for [54-1] motion for summary judgment, reset to 8/1/01 for [52-1] motion for partial summary judgment, reset to 8/1/01 for [50-1] motion for summary judgment ( signed by Magistrate Judge Joseph R. McCrorey ) (ttil) (Entered: 07/31/2001)

MOTION by defendant Graves Environmental, defendant Graves Construction, defendant Graves Water Service, defendant Graves Drilling Serv, defendant Graves Engineering to dismiss or, in the alternative, for summary judgment (ttil) (Entered: 08/02/2001)

MEMORANDUM by defendant Graves Environmental, defendant Graves Construction, defendant Graves Water Service, defendant Graves Drilling Serv, defendant Graves Engineering in support of [57-1] motion to dismiss or, in the alternative, for summary judgment w/ supporting appendix (ttil) Modified on 08/02/2001 (Entered: 08/02/2001)

MEMORANDUM by defendant Graves Environmental, defendant Graves Construction, defendant Graves Water Service, defendant Graves Drilling Services, defendant Graves Engineering in opposition to [52-1] motion for partial summary judgment w/supporting appendix (ttil) Modified on 08/02/2001 (Entered: 08/02/2001)

MEMORANDUM by plaintiff EEOC in opposition to [50-1] motion for summary judgment (ttil) (Entered: 08/02/2001)

MEMORANDUM by intervenor-plaintiff Betty J Kane in opposition to [50-1] motion for summary judgment (ttil) (Entered: 08/02/2001)

SUMMONS(ES) issued for defendant Graves Environmental, defendant Graves Construction, defendant Graves Water Service, defendant Graves Drilling Serv, defendant Graves Engineering (ttil) (Entered: 08/06/2001)

CONSENT ORDER extending time , Reply to Response to Motion reset to 8/17/01 for [57-1] motion to dismiss or, in the alternative, for summary judgment, reset to 8/17/01 for [54-1] motion for summary judgment, reset to 8/17/01 for [52-1] motion for partial summary judgment, reset to 8/17/01 for [50-1] motion for summary judgment ( signed by Magistrate Judge Joseph R. McCrorey ) (ttil) (Entered: 08/13/2001)

CONSENT ORDER extending time to file and serve replies to memoranda , Reply to Response to Motion reset to 8/31/01 for [57-1] motion to dismiss or, in the alternative, for summary judgment, reset to 8/31/01 for [54-1] motion for summary judgment, reset to 8/31/01 for [52-1] motion for partial summary judgment, reset to 8/31/01 for [50-1] motion for summary judgment ( signed by Magistrate Judge Joseph R. McCrorey ) (ttil) (Entered: 08/21/2001)

MOTION with memorandum in support by defendant Graves Construction, defendant Graves Water Service, defendant Graves Drilling Serv, defendant Graves Engineering to dismiss (ttil) (Entered: 08/28/2001)

REPLY MEMORANDUM by intervenor-plaintiff Betty J Kane to response to [57-1] motion to dismiss or, in the alternative, for summary judgment, [54-1] motion for summary judgment, [52-1] motion for partial summary judgment, [50-1] motion for summary judgment on integrated enterprise issue (ttil) (Entered: 08/28/2001)

AFFIDAVIT OF SERVICE of summons and complaint executed as to defendant Graves Construction, defendant Graves Water Service, defendant Graves Drilling Serv, defendant Graves Engineering 8/14/01 executed by certified mail (ttil) (Entered: 08/28/2001)

REPLY by plaintiff EEOC to response to [52-1] motion for partial summary judgment (ttil) (Entered: 09/04/2001)

MEMORANDUM by plaintiff EEOC in opposition to [66-1] motion to dismiss or in the alternative, for summary judgment (ttil) (Entered: 09/04/2001)

MOTION by plaintiff EEOC to strike [57-1] motion to dismiss or, in the alternative, for summary judgment (ttil) (Entered: 09/04/2001)

REPLY by defendant Graves Environmental, defendant Graves Construction, defendant Graves Water Service, defendant Graves Drilling Serv, defendant Graves Engineering to response to [66-1] motion to dismiss, [57-1] motion to dismiss or, in the alternative, for summary judgment, [50-1] motion for summary judgment (ttil) (Entered: 09/06/2001)

MOTION by defendant Graves Environmental, defendant Graves Construction, defendant Graves Water Service, defendant Graves Drilling Serv, defendant Graves Engineering to dismiss as a sanction for Betty Kane's willful dishonesty with Exhibits 1-10 (bbro) (Entered: 09/07/2001)

MEMORANDUM by plaintiff EEOC in opposition to [66-1] motion to dismiss (ttil) (Entered: 09/13/2001)

MOTION by plaintiff EEOC for Angela Grant to withdraw as attorney (dnap) (Entered: 09/25/2001)

ORDER extending time , Response to motion reset to 9/28/01 for [71-1] motion to dismiss as a sanction for Betty Kane's willful dishonesty ( signed by Magistrate Judge Joseph R. McCrorey ) (ttil) (Entered: 09/26/2001)

MEMORANDUM by plaintiff EEOC in opposition to [71-1] motion to dismiss as a sanction for Betty Kane's willful dishonesty (ttil) (Entered: 09/28/2001)

AFFIDAVIT of Angela R. Grant (ttil) (Entered: 09/28/2001)

MEMORANDUM by intervenor-plaintiff Betty J Kane in opposition to [71-1] motion to dismiss as a sanction for Betty Kane's willful dishonesty (ttil) (Entered: 10/01/2001)

REPLY by defendant Graves Environmental, defendant Graves Construction, defendant Graves Water Service, defendant Graves Drilling Serv, defendant Graves Engineering to response to [71-1] motion to dismiss as a sanction for Betty Kane's willful dishonesty (ttil) (Entered: 10/10/2001)

ORDER Specific Document Filing for EEOC to file an appropriate response on or before 11/01/01 to affidavit of attorney Angela Grant ( signed by Magistrate Judge Joseph R. McCrorey ) (ttil) (Entered: 10/25/2001)

ORDER directing plaintiff to file its response to the affidavit of Angela Grant until 11/7/01; EEOC may file its response without signature of local counsel( signed by Magistrate Judge Joseph R. McCrorey ) (ttil) (Entered: 11/07/2001)

RESPONSE by plaintiff EEOC to [77-1] affidavit of Angela Grant (ttil) (Entered: 11/08/2001)

REPLY by Angela Grant to the US EEOC's response to Angela Grant's Notice of Filing of Affidavit (dnap) Modified on 11/20/2001 (Entered: 11/20/2001)

MOTION by plaintiff EEOC for leave to file surreply (dnap) (Entered: 11/29/2001)

MOTION by plaintiff EEOC for protective order , to seal portions of the record (dnap) (Entered: 12/11/2001)

MOTION by plaintiff EEOC for leave to refile and substitute pleadings (dnap) (Entered: 12/11/2001)

RESPONSE by Angela R. Grant, former trial attorney for the EEOC, to [86-1] motion for leave to refile and substitute pleadings (dnap) (Entered: 12/17/2001)

RESPONSE to [85-1] motion for protective order, [85-2] motion to seal portions of the record (fbos) (Entered: 12/26/2001)

NOTICE of attorney appearance by Robert F. Daley, Jr. for the limited purpose of representing Mindy E. Weinstein, Lynette A. Barnes and Kara Gibbon Haden in their individual capacities as to the ethics inquiry arising out of the allegations made in the affidavit of Angela R. Grant (ttil) (Entered: 01/11/2002)

ORDER granting [86-1] motion for leave to refile and substitute pleadings, granting [85-1] motion for protective order, granting [85-2] motion to seal portions of the record, denying [84-1] motion for leave to file surreply, oral order granting [74-1] motion for Angela Grant to withdraw as attorney (Terminated, Angela Grant as attorney of record for the EEOC), denying [69-1] motion to strike [57-1] motion to dismiss or, in the alternative, for summary judgment ( signed by Magistrate Judge Joseph R. McCrorey ) (ttil) (Entered: 03/04/2002)

REPORT AND RECOMMENDATIONS of Magistrate Judge Joseph R. McCrorey recommending that Graves motion for summary judgment (Doc. #50) be denied, the EEOC's motion for partial summary judgment (Doc #52) be granted; Kane's motion for summary judgment (Doc #54) be granted; Graves motion to dismiss, or the alternative for summary judgment (Doc #57 be denied; Graves' motion to dismiss (Doc #66) be denied; and Graves' motion to dismiss base on Kane's dishonesty (Doc #71) be denied; Case no longer referred to Magistrate Judge Joseph R. McCrorey Objections to R and R due by 3/18/02 (ttil) (Entered: 03/04/2002)

SUPPLEMENTAL RESPONSE by plaintiff EEOC to [66-1] motion to dismiss (dnap) (Entered: 03/08/2002)

SUPPLEMENTAL RESPONSE by plaintiff EEOC to [57-1] motion to dismiss or, in the alternative, for summary judgment (dnap) (Entered: 03/08/2002)

SUPPLEMENTAL RESPONSE by plaintiff EEOC to [50-1] motion for summary judgment (dnap) (Entered: 03/08/2002)

MOTION by plaintiff EEOC to strike [57-1] motion to dismiss or, in the alternative, for summary judgment (dnap) (Entered: 03/08/2002)

MEMORANDUM by plaintiff EEOC in support of [94-1] motion to strike [57-1] motion to dismiss or, in the alternative, for summary judgment (dnap) (Entered: 03/08/2002)

OBJECTION by defendant Graves Environmental, defendant Graves Construction, defendant Graves Water Service, defendant Graves Drilling Serv, defendant Graves Engineering to [90-1] report and recommendations (mdea) (Entered: 03/19/2002)

REPLY by plaintiff EEOC to [96-1] objection (dnap) (Entered: 04/05/2002)

REPLY MEMORANDUM IN OPPOSITION by intervenor-plaintiff Betty J Kane to [96-1] objection (former empl) (Entered: 04/10/2002)

ORDER adopting R&R in part: granting in part, denying in part [71-1] motion to dismiss as a sanction for Betty Kane's willful dishonesty, denying [66-1] motion to dismiss, denying [57-1] motion to dismiss or, in the alternative, for summary judgment, denying [54-1] motion for summary judgment, denying [52-1] motion for partial summary judgment, granting in part, denying in part [50-1] motion for summary judgment; setting briefing schedule: defendants shall file motions or memoranda no later than 5/1/02; plaintiffs shall have normal response time; deadlines not subject to extension: set evidentiary hearing for 10:00 5/30/02 before Judge M. Currie ( signed by Judge Cameron M. Currie ) EOD 4-11-02 (former empl) (Entered: 04/11/2002)

NOTICE of Hearing set evidentiary hearing for 10:00 5/30/02 before Judge Cameron M. Currie (former empl) (Entered: 04/19/2002)

CORRENCTED NOTICE of Hearing set evidentiary hearing for 10:00 5/30/02 before Judge Cameron M. Currie (former empl) (Entered: 04/22/2002)

MOTION by plaintiff EEOC for Kara Gibbon Haden to withdraw as attorney (ttil) (Entered: 04/30/2002)