Case: EEOC v. Creative Networks, L.L.C.

EEOC v. Creative Networks, LLC

EEOC v. Creative Networks, LLC et al

EEOC v. Creative Networks, LLC et al

EEOC v. Creative Networks, LLC

EEOC v. Creative Networks, LLC

EEOC v. Creative Networks, LLC

EEOC v. Creative Networks, LLC

EEOC v. Creative Networks, LLC

Carly Knight, Frank Dobbin, Alexandra Kalev

COMPLAINT, filed by Equal Employment Opportunity Commission. (Attachments: # 1 Civil Cover Sheet)(Rosas, Lucila) (Entered: 09/30/2005)

1 Civil Cover Sheet

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Summons Issued as to Creative Networks, LLC, Res-Care, Inc.. (Attachments: # 1 Res-Care, Inc.)(ESH, ) (Entered: 10/04/2005)

1 Res-Care, Inc.

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SUMMONS Returned Executed by Equal Employment Opportunity Commission. Creative Networks, LLC served on 10/19/2005, answer due 11/8/2005; Res-Care, Inc. served on 10/19/2005, answer due 11/8/2005. (Attachments: # 1 Affidavit Service to Res-Care Inc.)(Rosas, Lucila) (Entered: 11/01/2005)

1 Affidavit Service to Res-Care Inc.

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NOTICE of Appearance by James Lawrence Blair on behalf of Creative Networks, LLC, Res-Care, Inc. (Blair, James) (Entered: 11/04/2005)

STIPULATION for Extension of Time for Defendants to File Responsive Pleading by Creative Networks, LLC, Res-Care, Inc.. (Blair, James) (Entered: 11/04/2005)

ORDER granting 5 STIPULATION for Extension of Time for Defendants to File Responsive Pleading by Creative Networks, LLC, Res-Care, Inc. (Blair, James) filed by Creative Networks, LLC, Res-Care, Inc.; Creative Networks, LLC answer due 11/18/2005; Res-Care, Inc. answer due 11/18/2005. Signed by Judge Stephen M McNamee on 11/7/05. (LSP) (Entered: 11/08/2005)

Answer of Creative Networks, LLC ANSWER to Complaint by Creative Networks, LLC.(Blair, James) (Entered: 11/18/2005)

Motion to Dismiss by Res-Care, Inc.. (Attachments: # 1 Exhibit 1# 2 Exhibit 1 Continued# 3 Exhibit 2)(Blair, James) Modified on 12/29/2005 (KCS). DOCKET MODIFIED TO CORRECT DOCUMENT TYPE TO MOTION TO DISMISS. (Entered: 11/18/2005)

1 Exhibit 1

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2 Exhibit 1 Continued

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3 Exhibit 2

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Standard Civil Track Initial ORDER . Signed by Judge Stephen M McNamee on 12/5/2005. (TCA, ) (Entered: 12/07/2005)

MEMORANDUM re: Opposition to Defendant Res-Care Inc's Motion to Dismiss Complaint re 8 Answer to Complaint by Plaintiff Equal Employment Opportunity Commission. (Rosas, Lucila) Modified on 12/29/2005 (KCS). DOCKET MODIFIED TO CORRECT DOCUMENT TYPE TO RESPONSE TO MOTION TO DISMISS. (Entered: 12/22/2005)

STIPULATION Stipulation to Extend Time for Defendant Res-Care, Inc.'s Reply to Plaintiff's Opposition to Motion to Dismiss (First Request) by Res-Care, Inc.. (Blair, James) (Entered: 12/23/2005)

NOTICE TO FILER OF DEFICIENCY re 8 Answer to Complaint filed by Res-Care, Inc.,. Description of deficiency: Incorrect document type selected. The docket has been modified to reflect PDF Motion to Dismiss. (KCS) (Entered: 12/29/2005)

NOTICE TO FILER OF DEFICIENCY re 10 Memorandum, filed by Equal Employment Opportunity Commission,. Description of deficiency: Incorrect document type selected. Docket modified to reflect PDF as Response to Motion to Dismiss. (KCS) (Entered: 12/29/2005)

ORDER granting stipulation for extension of time 11 ; ORDERED that dft's reply (to response to motion 8 ) shall be filed no later than 1/10/06. Signed by Judge Stephen M McNamee on 12/27/2005. (LAD) (Entered: 12/29/2005)

Reply re 10 Memorandum, Res-Care, Inc.'s Reply in Support of its Motion to Dismiss by Defendant Res-Care, Inc.. (Attachments: # 1 Exhibit 1)(Blair, James) (Entered: 01/10/2006)

1 Exhibit 1

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MOTION for Extension of Time Leave to Accept Responsive Pleading Filed Outside of Responsive Time Period by Equal Employment Opportunity Commission. (Rosas, Lucila) (Entered: 01/11/2006)

ORDER granting 16 Motion for Extension of Time for Defendants to File Responsive Pleading to Plaintiff's Complaint. Dft shall have until 11/18/05 to file their response. Signed by Judge Roslyn O Silver on 01/17/06. (DNH, ) (Entered: 01/17/2006)

NOTICE of Attorney Substitution by Sally Clifford Shanley (Shanley, Sally) (Entered: 03/02/2006)

MEMORANDUM OF DECISION AND ORDER denying re 8 Res-Care's Motion to Dismiss. ORDERED that the Court Deputy shall schedule and issue an order setting a Rule 16 Preliminary Pretrial Conference pursuant to Fed.R.Civ.P. 16(b). Signed by Judge Stephen M McNamee on 12/29/06. (TLJ) (Entered: 12/29/2006)

ORDER Scheduling Conference set for 3/1/2007 04:00 PM in Courtroom 605, 401 West Washington Street, Phoenix, AZ 85003 before Judge Stephen M McNamee.. Signed by Judge Stephen M McNamee on 12/29/2006. (TCA, ) (Entered: 01/03/2007)

NOTICE of Attorney Substitution by Neil Todd McKay (McKay, Neil) (Entered: 01/16/2007)

ANSWER to Complaint with Jury Demand of Res-Care, Inc. by Creative Networks, LLC, Res-Care, Inc..(Blair, James) (Entered: 01/16/2007)

REPORT re: Rule 26(f) Planning Meeting by Equal Employment Opportunity Commission, Creative Networks, LLC, Res-Care, Inc.. (Rosas, Lucila) (Entered: 02/22/2007)

First MOTION for Telephonic Appearance of Out-of-State Representative at Rule 16 Preliminary Pretrial Conference by Res-Care, Inc.. (Attachments: # 1 Text of Proposed Order)(Blair, James) (Entered: 02/23/2007)

1 Text of Proposed Order

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ORDER granting 24 Defendant Res-Care, Inc.'s Motion for Telephonic Appearance of Out-of-state Representative. Signed by Judge Stephen M McNamee on 2/23/07.(TLJ) (Entered: 02/26/2007)

Minute Entry. Proceedings held before Judge Stephen M McNamee : Apr. Lucila Rosas for pla, clients Rhonda Encinas-Castro and Kathryn Allen present;James Blair for dfts, Client Ron Cornelison present, Deana Ombre telephonic for dftsScheduling Conference held on 3/1/2007.Final Pretrial Conference set for 4/2/2008 04:00 PM in Courtroom 605, 401 West Washington Street, Phoenix, AZ 85003 before Judge Stephen M McNamee. Order to Follow. (Court Reporter Gary Moll.) This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry. (TCA, ) (Entered: 03/02/2007)

Notice re Service of Initial Rule 26(a)(1) Disclosures by Equal Employment Opportunity Commission (Rosas, Lucila) (Entered: 03/02/2007)

Notice re Service of Defendants' Initial Disclosure Statement by Creative Networks, LLC, Res-Care, Inc. (Blair, James) (Entered: 03/02/2007)

SCHEDULING ORDER: Discovery due by 2/1/2008.,Dispositive motions due by 3/7/2008., Final Pretrial Conference set for 4/2/2008 04:00 PM before Judge Stephen M McNamee.. Signed by Judge Stephen M McNamee on 3/1/07. (TLJ) (Entered: 03/05/2007)

Notice re Service of Defendants' First Supplemental Disclosure Statement by Creative Networks, LLC, Res-Care, Inc. (Blair, James) (Entered: 03/29/2007)

NOTICE of Appearance by Utiki Y Spurling on behalf of all defendants (Spurling, Utiki) (Entered: 04/10/2007)

Notice re Notice of Service of Discovery by Creative Networks, LLC, Res-Care, Inc. (Spurling, Utiki) (Entered: 04/20/2007)

NOTICE of Deposition of Rhonda L. Encinas-Castro, filed by Creative Networks, LLC, Res-Care, Inc.. (Spurling, Utiki) (Entered: 05/08/2007)

NOTICE of Deposition of Kathryn A. Allen, filed by Creative Networks, LLC, Res-Care, Inc.. (Spurling, Utiki) (Entered: 05/08/2007)

NOTICE of Deposition of Ron Cornelison, filed by Equal Employment Opportunity Commission. (Rosas, Lucila) (Entered: 05/22/2007)

Notice re Service of Discovery by Creative Networks, LLC, Res-Care, Inc. (Spurling, Utiki) (Entered: 05/29/2007)

Notice re Service of Discovery Responses to Defendant by Equal Employment Opportunity Commission (Rosas, Lucila) (Entered: 06/20/2007)

Notice re Service of Defendants' Second Supplemental Disclosure Statement by Creative Networks, LLC, Res-Care, Inc. (Blair, James) (Entered: 06/21/2007)

STIPULATION re Confidentiality of Kathryn Allen's Medical Records by Equal Employment Opportunity Commission. (Attachments: # 1 Text of Proposed Order)(Rosas, Lucila) (Entered: 07/11/2007)

1 Text of Proposed Order

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ORDER regarding confidentiality of medical records pursuant to 39 Stipulation. Signed by Judge Stephen M McNamee on 7/12/07. (TLJ) (Entered: 07/12/2007)

Notice re Service of Discovery by Creative Networks, LLC, Res-Care, Inc. (Spurling, Utiki) (Entered: 07/12/2007)

Notice re Service of First Discovery Requests by Equal Employment Opportunity Commission (Rosas, Lucila) (Entered: 07/12/2007)

Notice re Service of Second Discovery Responses by Equal Employment Opportunity Commission (Rosas, Lucila) (Entered: 07/12/2007)

Notice re Service of Supplemental Response to Discovery by Equal Employment Opportunity Commission (Rosas, Lucila) (Entered: 07/13/2007)

Notice re Notice of Service of Discovery Responses by Creative Networks, LLC, Res-Care, Inc. (Spurling, Utiki) (Entered: 08/07/2007)

NOTICE of Deposition of Custodian of Records for Robert Bevan, MD, filed by Creative Networks, LLC, Res-Care, Inc.. (Spurling, Utiki) (Entered: 08/21/2007)

Notice re Notice of Service of Defendants' Third Supplemental Disclosure Statement by Creative Networks, LLC, Res-Care, Inc. (Spurling, Utiki) (Entered: 10/10/2007)

NOTICE of Attorney Substitution by James Lawrence Blair, Sandra A Shoupe-Gorga adding Sandra A Shoupe-Gorga and James Lawrence Blair for Creative Networks, LLC and Res-Care, Inc. (Blair, James) (Entered: 10/29/2007)

Notice re of Service by Equal Employment Opportunity Commission of 4th Supplemental Disclosure Statement (Rosas, Lucila) (Entered: 01/10/2008)

NOTICE of Deposition of Melanie Butler, filed by Creative Networks, LLC, Res-Care, Inc.. (Shoupe-Gorga, Sandra) (Entered: 01/17/2008)

NOTICE of Deposition of Bonnie Cooper, filed by Creative Networks, LLC, Res-Care, Inc.. (Shoupe-Gorga, Sandra) (Entered: 01/17/2008)

NOTICE of Deposition of Ginger Call, filed by Equal Employment Opportunity Commission. (Rosas, Lucila) (Entered: 01/18/2008)

NOTICE of Deposition of Linda Leary, filed by Equal Employment Opportunity Commission. (Rosas, Lucila) (Entered: 01/22/2008)

NOTICE of Deposition of Melanie Butler, filed by Creative Networks, LLC, Res-Care, Inc.. (Shoupe-Gorga, Sandra) (Entered: 01/22/2008)

NOTICE of Deposition of Robert P. Bevan, MD, filed by Creative Networks, LLC, Res-Care, Inc.. (Shoupe-Gorga, Sandra) (Entered: 01/23/2008)

NOTICE of Deposition of Megan Neal, filed by Equal Employment Opportunity Commission. (Rosas, Lucila) (Entered: 01/25/2008)

STIPULATION For One Week Extension of Discovery Cut-Off Deadline (Joint) (First Request) by Equal Employment Opportunity Commission. (Attachments: # 1 Text of Proposed Order)(Rosas, Lucila) (Entered: 01/28/2008)

1 Text of Proposed Order

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NOTICE of Deposition of Freda Smith, filed by Equal Employment Opportunity Commission. (Rosas, Lucila) (Entered: 01/28/2008)

Minute Entry. Proceedings held before Judge Stephen M McNamee: Apr. Lucila Rosas for pla, Sandra Shoupe-Gorga for dftsTelephone Discovery Dispute Conference held on 1/28/2008.Plaintiff request to quash subpoena of Dr. Bevan is denied;Defendants subpoena for post and prior employers is granted. Plaintiff to sign the appropriate releases. Defendant is entitled to 5 prior employers 5 years back and all post employers. Due by 2/29/2008. (Court Reporter Gary Moll.) This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry. (TCA, ) (Entered: 01/28/2008)

Notice re Notice of Service of Defendants' Fourth Supplemental Disclosure Statement by Creative Networks, LLC, Res-Care, Inc. (Shoupe-Gorga, Sandra) (Entered: 01/28/2008)

ORDER granting the parties' stipulation 57 for a one week extension of the discovery cut-off deadline. Discovery due by 2/9/2008. Signed by Judge Stephen M McNamee on 1/29/08. (TLJ) (Entered: 01/29/2008)

NOTICE of Deposition of Bonnie Cooper (First Amended), filed by Creative Networks, LLC, Res-Care, Inc.. (Shoupe-Gorga, Sandra) (Entered: 01/29/2008)

Minute Order: ORDEREDTelephone Discovery Dispute Conference set for 1/31/2008 01:30 PM in Courtroom 605, 401 West Washington Street, Phoenix, AZ 85003 before Judge Stephen M McNamee. This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry. (TCA, ) (Entered: 01/30/2008)

NOTICE of Deposition of Res-Care, Inc., filed by Equal Employment Opportunity Commission. (Rosas, Lucila) (Entered: 01/31/2008)

Minute Entry. Proceedings held before Judge Stephen M McNamee: Telephonic Apr. Lucila Rosas for pla, James Blair for dft CreativeTelephone Discovery Dispute Conference held on 1/31/2008. Deposition of Edna Faulkner to be taken no later than 2/22/2008. (Court Reporter Merilyn Sanchez.) This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry. (TCA, ) (Entered: 01/31/2008)

Notice re of Service of Plaintiff EEOC's Fifth Supplemental Disclosure Statement by Equal Employment Opportunity Commission (Rosas, Lucila) (Entered: 01/31/2008)

Notice re Service of Defendants' Fifth Supplemental Disclosure Statement by Creative Networks, LLC, Res-Care, Inc. (Blair, James) (Entered: 02/01/2008)

NOTICE of Deposition of Edna Faulkner, filed by Equal Employment Opportunity Commission. (Rosas, Lucila) (Entered: 02/13/2008)

STIPULATION TO EXTEND DEPOSITION AND DISPOSITIVE MOTION DEADLINES by Res-Care, Inc.. (Shoupe-Gorga, Sandra) (Entered: 02/19/2008)

ORDER that the time in which to depose out of state witness shall be extended to 3/28/08. Dispositive motion deadline extended to 4/11/08 re: stipulation 69 . Signed by Judge Stephen M McNamee on 2/20/08. (TLJ) (Entered: 02/20/2008)

NOTICE of Deposition of Custodian of Records, Fowler School District, filed by Creative Networks, LLC, Res-Care, Inc.. (Shoupe-Gorga, Sandra) (Entered: 02/21/2008)

NOTICE of Deposition of Custodian of Records, Valle del Sol, filed by Creative Networks, LLC, Res-Care, Inc.. (Shoupe-Gorga, Sandra) (Entered: 02/21/2008)

NOTICE of Deposition of Custodian of Records, Value Options, Inc., filed by Creative Networks, LLC, Res-Care, Inc.. (Shoupe-Gorga, Sandra) (Entered: 02/21/2008)

NOTICE of Deposition of Custodian of Records, Goodwill, filed by Creative Networks, LLC, Res-Care, Inc.. (Shoupe-Gorga, Sandra) (Entered: 02/21/2008)

NOTICE of Deposition of Custodian of Records, ASU West, filed by Creative Networks, LLC, Res-Care, Inc.. (Shoupe-Gorga, Sandra) (Entered: 02/21/2008)

NOTICE of Deposition of Custodian of Records, Glendale Community College, filed by Creative Networks, LLC, Res-Care, Inc.. (Shoupe-Gorga, Sandra) (Entered: 02/21/2008)

NOTICE of Deposition of Custodian of Records, Arizona Dept. of Economic Security, filed by Creative Networks, LLC, Res-Care, Inc.. (Shoupe-Gorga, Sandra) (Entered: 02/26/2008)

NOTICE of Deposition of Custodian of Records, Touchstone Behavioral Health, filed by Creative Networks, LLC, Res-Care, Inc.. (Shoupe-Gorga, Sandra) (Entered: 02/26/2008)

NOTICE of Deposition of Custodian of Records, Tungland Corporation, filed by Creative Networks, LLC, Res-Care, Inc.. (Shoupe-Gorga, Sandra) (Entered: 02/26/2008)

NOTICE of Deposition of Custodian of Records, Devereux Arizona, filed by Creative Networks, LLC, Res-Care, Inc.. (Shoupe-Gorga, Sandra) (Entered: 02/26/2008)

NOTICE of Deposition of Custodian of Records, West Valley Child Crisis Center, filed by Creative Networks, LLC, Res-Care, Inc.. (Shoupe-Gorga, Sandra) (Entered: 02/26/2008)

STIPULATION Stipulation to Extend Deadline to Obtain Employment Records by Res-Care, Inc.. (Shoupe-Gorga, Sandra) (Entered: 02/27/2008)

Minute Order: ORDERED Final Pretrial Conference re-set for 5/21/2008 04:00 PM in Courtroom 605, 401 West Washington Street, Phoenix, AZ 85003 before Judge Stephen M McNamee. This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry. (TCA, ) (Entered: 02/28/2008)

ORDER that the deadline to obtain employment records shall be extended to 3/27/08 re 82 STIPULATION. Signed by Judge Stephen M McNamee on 2/29/08. (TLJ) (Entered: 02/29/2008)

NOTICE of Deposition of Edna Faulkner, filed by Equal Employment Opportunity Commission. (Rosas, Lucila) (Entered: 03/03/2008)

ORDER that no later than 3/21/08 counsel shall file simultaneous written briefs. Signed by Judge Stephen M McNamee on 3/12/08. (TLJ) (Entered: 03/13/2008)

ORDER re: Proposed Pretrial Order due by 4/11/2008. Signed by Judge Stephen M McNamee on 3/14/08. (TLJ) (Entered: 03/14/2008)

ORDERED Proposed Pretrial Order due by 4/11/2008. Signed by Judge Stephen M McNamee on 3/14/08. (TLJ) (Entered: 03/14/2008)

TEXT-ONLY Minute Order: The Court hereby modifies its Order filed 3/14/08 as follows: The proposed pretrial order shall be filed by 4/18/08; Motions in Limine shall be filed by 4/18/08; Responses to Motions in Limine shall be filed by 4/25/08. The remainder of the Order of 3/14/08 is AFFIRMED and remains in effect. This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry. (SJF) (Entered: 03/17/2008)

BRIEF RE: EX PARTE CONTACT WITH FORMER SUPERVISORS by Defendants Creative Networks, LLC, Res-Care, Inc.. (Attachments: # 1 Exhibit A)(Blair, James) (Entered: 03/21/2008)

1 Exhibit A

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BRIEF Re: Discovery Dispute Re: Ex Parte Communications by Plaintiff Equal Employment Opportunity Commission. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3)(Rosas, Lucila) (Entered: 03/21/2008)

1 Exhibit 1

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2 Exhibit 2

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3 Exhibit 3

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Notice re Notice of Service of Defendants' Sixth Supplemental Disclosure Statement by Creative Networks, LLC, Res-Care, Inc. (Shoupe-Gorga, Sandra) (Entered: 03/27/2008)

MOTION for Summary Judgment by Res-Care, Inc.. (Blair, James) (Entered: 04/11/2008)

STATEMENT of Undisputed Facts in Support of its Motion for Summary Judgment re 93 MOTION for Summary Judgment by Defendant Res-Care, Inc.. (Attachments: # 1 Exhibit A - F, # 2 Exhibit G, # 3 Exhibit H - I)(Blair, James) (Entered: 04/11/2008)

1 Exhibit A - F

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2 Exhibit G

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3 Exhibit H - I

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MOTION for Partial Summary Judgment Regarding Defendants Affirmative Defenses by Equal Employment Opportunity Commission. (Rosas, Lucila) (Entered: 04/11/2008)

STATEMENT of Facts in Support of Plaintiff's Motion for Summary Judgment re 95 MOTION for Partial Summary Judgment Regarding Defendants Affirmative Defenses by Plaintiff Equal Employment Opportunity Commission. (Attachments: # 1 Exhibit # 1- 6 and Attachments A - E)(Rosas, Lucila) (Entered: 04/11/2008)

1 Exhibit # 1- 6 and Attachments A - E

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MOTION for Partial Summary Judgment by Creative Networks, LLC. (Shoupe-Gorga, Sandra) (Entered: 04/11/2008)

STATEMENT Separate Statement of Undisputed Facts in Support of Its Motion for Summary Judgment by Defendant Creative Networks, LLC. (Shoupe-Gorga, Sandra) (Entered: 04/11/2008)

Minute Order: ORDERED vacating the final pretrial conference set for May 21, 2008, to be reset if necessary, upon the resolution of the dispositive motions. This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry. (TCA, ) (Entered: 04/18/2008)

MOTION for Extension of Time To Extend Time to Respond (Unopposed) by Equal Employment Opportunity Commission. (Attachments: # 1 Text of Proposed Order to Extend Time)(Rosas, Lucila) (Entered: 04/25/2008)

1 Text of Proposed Order to Extend Time

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