Case: EEOC v. LE BAR BAT, INC.

EEOC v. Le Bar Bat, Inc.

E.E.O.C. v. Die Fliedermaus

E.E.O.C. v. Le Bar Bat, Inc.

EEOC v. Le Bar Bat

Carly Knight, Frank Dobbin, Alexandra Kalev

COMPLAINT filed; Summons issued and Notice pursuant to 28 U.S.C. 636(c); FILING FEE $ USA (bm) (Entered: 03/11/1999)

Magistrate Judge Ellis is so Designated. (bm) (Entered: 03/11/1999)

NOTICE OF MOTION by Die Fliedermaus dismissing the complaint ; staying the proceeding pending mandatory conciliation bye EEOC Return date not indicated (cd) (Entered: 05/13/1999)

MEMORANDUM by Die Fliedermaus in support of [2-1] motion dismissing the complaint, [2-2] motion staying the proceeding pending mandatory conciliation bye EEOC (cd) (Entered: 05/13/1999)

Filed Memo-Endorsement on letter addressed to Judge Sweet from Joyce E. Levowitz, dated 6/4/99; pltff's response to deft's motion reset to 7/2/99 for [2-1] motion dismissing the complaint, reset to 7/2/99 for [2-2] motion staying the proceeding pending mandatory conciliation bye EEOC ; deft's reply to response to motion reset to 7/23/99 for [2-1] motion dismissing the complaint, reset to 7/23/99 for [2-2] motion staying the proceeding pending mandatory conciliation bye EEOC ; the return date will be adjourned until Wednesday, 8/4/99 for [2-1] motion dismissing the complaint, 8/4/99 for [2-2] motion staying the proceeding pending mandatory conciliation bye EEOC. ( signed by Judge Robert W. Sweet ); Copies mailed. (sac) (Entered: 06/18/1999)

Memo endorsed on motion; granting [2-1] motion dismissing the complaint; granting [2-2] motion staying the proceeding pending mandatory conciliation bye EEOC; no opposition; submit order on notice ( signed by Judge Robert W. Sweet ); Copies mailed. (pl) (Entered: 06/25/1999)

ORDER, the Order of June 23, 1999 is vacated ; Defendant's motion purs to Rule 12(b)(6) to dismiss plaintiff's complaint is now returnable on September 15, 1999. (signed by Judge Robert W. Sweet); Copies mailed. (djc) (Entered: 07/07/1999)

NOTICE OF MOTION by Angela Boggs, Kimberly Hawkes, Shereece Holman, Staci Pollard, Rhonda Roenfeldt, Madilyn Wade for an order pursuant to Rules 24(a) and 42(a) FRCP, granting their motion to permit each of them to intervene in the EEOC action based upon the charges they previously filed with the EEOC , return date 8/11/99 at 12:00 noon (affidavit of Elizabeth A. Mason in support attached) (ri) (Entered: 07/28/1999)

MEMORANDUM of LAW by Angela Boggs, Kimberly Hawkes, Shereece Holman, Staci Pollard, Rhonda Roenfeldt, Madilyn Wade in support of [6-1] motion for an order pursuant to Rules and 42(a) FRCP, granting their motion to permit each of to intervene in the EEOC action based upon the charges they previously filed with the EEOC (ri) (Entered: 07/28/1999)

MEMORANDUM by E.E.O.C. in opposition to [2-1] motion dismissing the complaint (cd) (Entered: 08/03/1999)

DECLARATION of Elizabeth Grossman by E.E.O.C. in support Re: [8-1] opposition memorandum . (cd) (Entered: 08/03/1999)

REPLY MEMORANDUM by Die Fliedermaus re: [2-1] motion dismissing the complaint; and statement in response to pltffs' motion to intervene and consolidate. (jp) (Entered: 08/17/1999)

Memo endorsed on motion, document number 6; motion adjourned by consent to 9/15/99 for [6-1] motion for an order pursuant to Rules 24(a) and 42(a) FRCP, granting their motion to permit each of them to intervene in the EEOC action based upon the charges they previously filed with the EEOC ( signed by Judge Robert Sweet ); Copies mailed. (jp) (Entered: 08/24/1999)

REPLY MEMORANDUM by Die Fliedermaus re: in support of [2-1] motion dismissing the complaint; [2-2] motion staying the proceeding pending mandatory conciliation bye EEOC (ls) (Entered: 08/30/1999)

AFFIDAVIT of Joyce E. Levowitz by Die Fliedermaus in support Re: [2-1] motion dismissing the complaint, [2-2] motion staying the proceeding pending mandatory conciliation bye EEOC (ls) (Entered: 08/30/1999)

RULE 1.9 CERTIFICATE filed by Le Bar Bat, Inc. (sn) (Entered: 09/14/1999)

ANSWER to Complaint by Le Bar Bat, Inc. (Attorney Daniel S. Greenfeld from the Firm: Parker, Chapin, Flattau & Klimpl, L.L.P.). (sn) (Entered: 09/14/1999)

NOTICE of attorney appearance for E.E.O.C. by Sunu P. Chandy (jp) (Entered: 12/27/1999)

NOTICE of Order of Consolidation by Angela Boggs, Kimberly Hawkes et all on 1/3/00 (cd) (Entered: 01/10/2000)

NOTICE OF ORDER Of Consolidation; that the following actions 99 Civ. 1732 (RWS) and 99 Civ. 2451 (RWS) are consolidated (for all pretrial purposes (as per chmbrs. on 2/7/00)) ; ( signed by Judge Robert W. Sweet ); copies mailed (ls) (Entered: 02/07/2000)

ANSWER to Complaint by Matt Tortoso (Attorney Daniel S. Greenfeld from the Firm: Morvillo Abramowitz); (orig. docketed in 99cv2451, doc #45) (cd) (Entered: 01/31/2000)

STIPULATION and ORDER; that the time for defts Colin Walsh and Matt Tortoso (in action #99 cv 2451), to answer the complaint is extended to and including 1/31/00, with service upon the pltff's atty to be by facsimile, and that no further extensions to answer the complaint shall be requested . ( signed by Judge Robert W. Sweet ) (jp) (Entered: 02/01/2000)

Pretrial Conference held before Judge Robert W. Sweet . (jp) (Entered: 02/04/2000)

ANSWER to Complaint by Simon Azoulay; (Attorney Joel Spivak from the Firm: The Office of Joel Spivak). (pl) (Entered: 05/23/2000)

ANSWER to Complaint by Die Fliedermaus; (Attorney Richard A. Wilsker from the Firm: Ross & Hardies). (pl) (Entered: 05/23/2000)

ANSWER to Complaint of Boggs, Hawkes, Holman, Pollard, Roenfeldt and Wade by Die Fliedermaus and Gerald J. Shallo's; (Attorney Richard A. Wilsker from the Firm: Ross & Hardies). (pl) (Entered: 05/23/2000)

ORDER, that the parties shall complete all discovery, inspection and motions by 1/17/01; The parties shall submit to the Court trial briefs, a joint proposed pretrial order, and if applicable, proposed jury charges and voir dire requests in accordance with the annexed form and instructions by 1/30/01; A final pretrial conference will be held on 1/30/01 at 4:30 p.m. and the action shall be added to the trial calendar published in the New York Law Journal . ( signed by Judge Robert W. Sweet ); Copies mailed. (ri) Modified on 06/26/2000 (Entered: 06/22/2000)

NOTICE OF MOTION by Ross & Hardies counsel for defts Die Fliedermaus LLC and Gerald J. Shallo; for an order relieving it and attnys. Richard A. Wilsker, Catherine A. Rogers, and Joyce E. Levowitz, as attnys. of record for defts Die Fliedermaus LLC and Gerald J. Shallo ; and for an order awarding Ros & Hardies the fees and disbursements owed by defts ; Return date not indicated (lf) (Entered: 01/05/2001)

MEMORANDUM OF LAW by Ropss & Hardies' attnys. for deftsDie Fliedermaus LLC and Gerald J. Shallo in support of [23-1] motion for an order relieving it and attnys. Richard A. Wilsker, Catherine A. Rogers, and Joyce E. Levowitz, as attnys. of record for defts Die Fliedermaus LLC and Gerald J. Shallo; [23-2] motion for an order awarding Ros & Hardies the fees and disbursements owed by defts. (lf) (Entered: 01/05/2001)

AFFIDAVIT of Richard A. Wilsker, Esq. by Ross & Hardies attnys. for deftsDie Fliedermaus LLC and Gerald J. Shallo in support of [23-1] motion for an order relieving it and attnys. Richard A. Wilsker, Catherine A. Rogers, and Joyce E. Levowitz, as attnys. of record for defts Die Fliedermaus LLC and Gerald J. Shallo; [23-2] motion for an order awarding Ros & the fees and disbursements owed by defts. (lf) (Entered: 01/05/2001)

STIPULATION and ORDER; regarding procedures that will govern the handling of "Confidential Materials" . ( signed by Judge Robert W. Sweet ) (pl) (Entered: 01/19/2001)

NOTICE OF MOTION by Hoguet Newman & Regal, LLP; for an order granting Hoguet Newman & Regal, LLP's motion to withdraw as counsel for deft Larry Cerrone ; for an award of the Attny fees and disbursements owed to Hoguet Newman & Regal, LLP ; Return date 1/17/01. (lf) Modified on 01/23/2001 (Entered: 01/23/2001)

STIPULATION and ORDER of substituion of counsel; that Annmarie P. Venuti shall be substituted as attorney of record for defts Die Fliedermaus in place and stead of Ross & Hardies ( signed by Judge Robert W. Sweet ) (lam) (Entered: 02/06/2001)

Memo endorsed on motion; granting [23-1] motion for an order relieving it and attnys. Richard A. Wilsker, Catherine A. Rogers, and Joyce E. Levowitz, as attnys. of record for defts Die Fliedermaus LLC and Gerald J. Shallo; the fee issue will be submitted at the convenience of counsel . ( signed by Judge Robert W. Sweet ); Copies mailed. (kw) (Entered: 02/06/2001)

Memo endorsed on motion; granting [27-1&2] motion for an order granting Hoguet Newman & Regal, LLP's motion to withdraw as counsel for deft Larry Cerrone; motion granted to withdraw. Fees and disbursements issue to be submitted at the convenience of counsel. So Ordered. ( signed by Judge Robert W. Sweet ); Copies mailed. (jp) (Entered: 02/09/2001)

ORDER; All motions are to be made returnable at 12:00 noon on Wednesday and in compliance with the rules of this the parties shall complete all discovery, inspection and motions by 07/17/01; The parties shall submit to the court trial briefs, a joint proposed pretrial order, and, if applicable, proposed jury charges and voir dire requests in accordance with the annexed form and instructions by 07/24/01; A final pretrial confernce will be held at 4:30 p.m. on 07/24/01 and the action shall be added to the trial calendar published in the New York Law Journal ; ( signed by Judge Robert W. Sweet ); Copies mailed. (djc) Modified on 02/21/2001 (Entered: 02/20/2001)

ORDER; reset discovery due for 7/17/01, as stated during the 1/31/01 court conference . ( signed by Judge Lawrence M. McKenna ); Copies mailed. (pl) (Entered: 02/21/2001)

Memo-Endorsement on letter addressed to Judge Sweet from Annmarie P. Venuti, dated 2/20/01; response to motion reset to 3/8/01 for [23-2] motion for an order awarding Ross & Hardies the fees and disbursements owed by defts (signed by Judge Robert W. Sweet ); Copies mailed. (lam) (Entered: 03/09/2001)

AFFIDAVIT of deft Gerald J. Shallo (case #99cv2451) in opposition to [23-2] motion to award Ross & Hardies the fees and disbursements owed by defts. (lam) (Entered: 03/13/2001)

MEMORANDUM OF LAW filed by Gerald J. Shallo (case #99cv2451) in opposition to [23-2] motion to award Ross & Hardies the fees and disbursements owed by defts. (lam) (Entered: 03/13/2001)

Memo-Endorsement on letter addressed to Judge Sweet from the Law Firm of Ross & Hardies, dated 3/12/01. Re:, former counsel for dft's Die Fliedermaus, L.L.C. and Gerald J. Shallo write to the Court to confirm the teldphone converstioan regarding motion for fees and costs dated 1/3/01; sealing is granted, a copy will be served on counsel for Shallo . ( signed by Judge Robert W. Sweet ); Copies mailed. (pl) (Entered: 03/27/2001)

SEALED DOCUMENT placed in vault. (af) (Entered: 04/04/2001)

SEALED DOCUMENT placed in vault. (af) (Entered: 04/04/2001)

STIPULATION AND ORDER; substituting AnnMarie P. Venuti, Esq. in place of Ross & Hardies as counsel of record for deft, Gerald J. Shallo. ( signed by Judge Robert W. Sweet ) (sac) (Entered: 04/05/2001)

NOTICE OF REDESIGNATION OF A CIVIL CASE TO ANOTHER MAGISTRATE JUDGE. The above entitled action has been redesignated to Magistrate Judge Gabriel W. Gorenstein. Please note that this is a reassignment of the designation only. Copy of notice mailed to Attorney(s) of record: Elizabeth A. Mason, Annmarie P. Venuti, Richard A. Wilsker, Daniel S. Greenfeld, Sunu P. Chandy, Elizabeth A. Grossman. (db) (Entered: 04/11/2001)

Order that case be referred to the Clerk of Court for assignment to a Magistrate Judge for Gen. Pretrial/After Initial Case Mgmt. Conference; Referred to Magistrate Judge Gabriel W. Gorenstein. ( signed by Judge Robert W. Sweet ) (pl) (Entered: 04/12/2001)

SEALED DOCUMENT placed in vault. (rp) (Entered: 04/24/2001)

SEALED DOCUMENT placed in vault. (rp) (Entered: 05/31/2001)

SEALED DOCUMENT placed in vault. (wv) (Entered: 06/25/2001)

SEALED DOCUMENT placed in vault. (rp) (Entered: 07/12/2001)

Memo-Endorsement on letter addressed to Judge Sweet from Sunu P. Chandy, dated 7/5/01; reset discovery cutoff to 9/17/01 on which date the pre-trial order will be filed; no plaintiff will testify without being deposed prior to testimony . ( signed by Judge Robert W. Sweet ); Copies mailed. (pl) (Entered: 07/13/2001)

Terminated document 23-2 pursuant to instructions of Judge Sweet. (rag) (Entered: 08/06/2001)

ORDER, the EEOC and Intervening plntfs be permitted to depose by videotape Patrick Kelly, ID #45980-054, currently incarcerated in F.P.C. Allenwood, on 8/30 and 31/01, or on alternative dates which are mutually agreeable to the parties ( signed by Judge Robert W. Sweet ); Copies mailed. (cd) (Entered: 08/14/2001)

Pretrial Conference held before Magistrate Judge Gabriel W. Gorenstein. (kw) (Entered: 08/15/2001)

ORDER; that pursuant to Local Rule 1.4 of the United States District Court of the Southern District of New York, it is Ordered that Morvillo, Abramowitz, Grand, Iason & Silberberg P.C.'s motion for leave to withdraw as counsel to Matthew Tortoso is granted . ( signed by Judge Robert W. Sweet ); Copies mailed. (kkc) (Entered: 08/17/2001)

NOTICE OF MOTION by Larry Cerrone for an order purs. to Rule 37 of the F.R.C.P. granting full disclosure and service of all documents, either originals or copies thereof described herein . Return date 8/24/01. Affidavit of Laurent M. Cerrone attached. (sn) (Entered: 08/24/2001)

NOTICE OF MOTION by Le Bar Bat, Inc.; for an Order pursuant to Rule 56(b) of the FRCP granting summary judgment . Return date 9/12/01. Affidavit of Stephen Grabow attached. (kkc) (Entered: 08/30/2001)

MEMORANDUM OF LAW by Le Bar Bat, Inc. in support of [50-1] motion for an Order pursuant to Rule 56(b) of the FRCP granting summary judgment. (kkc) (Entered: 08/30/2001)

ORDER; all motions are to be made returnable at 12:00 noon on Wed. and in compliance with the rules of this Court. The parties shall complete all discovery, inspection and motions by 11/19/01. The parties shall submit to the court trial briefs, a joint proposed pretrial order, and, if applicable, proposed jury charges and voir dire requests by 12/3/01. A final pretrial conference will be held at 4:30 PM on that date and the action shall be added to the trial calendar published in the NY Law Journal. The parties are directed to be ready for trial the day after the pretrial order is due and, upon receipt of 24-hour telephone notice, on any day thereafter . ( signed by Judge Robert W. Sweet ); Copies mailed. (sn) (Entered: 09/07/2001)

SEALED DOCUMENT placed in vault. (rp) (Entered: 10/01/2001)

STIPULATION and ORDER, Return date reset to 10/31/01 [50-1] motion for an Order pursuant to Rule 56(b) of the FRCP granting summary judgment ; Plntf's Response to motion reset to 10/24/01 [50-1] motion for an Order pursuant to Rule 56(b) of the FRCP granting summary judgment ; Deft Le Bar Bat's Reply to Response to Motion reset to 10/30/01 [50-1] motion for an Order pursuant to Rule 56(b) of the FRCP granting summary judgment ( signed by Judge Robert W. Sweet ); (cd) (Entered: 10/10/2001)

Pretrial Conference held before Magistrate Judge Theodore H. Katz. (db) (Entered: 10/17/2001)

NOTICE of appearance by Laurent M. Cerrone (bai) (Entered: 10/17/2001)

Telephone Conference held before Magistrate Judge Gabriel W. Gorenstein. (kw) (Entered: 10/22/2001)

SEALED DOCUMENT placed in vault. (wv) (Entered: 10/25/2001)

Memo-Endorsement on letter addressed to Judge Sweet from Judy Keenan, dated 10/17/01, EEOC's Response to motion reset to 11/29/01 for [50-1] motion for an Order pursuant to Rule 56(b) of the FRCP granting summary judgment ( signed by Judge Robert W. Sweet ); Copies mailed. (cd) (Entered: 11/02/2001)

STIPULATION AND ORDER of dismissal of the action as to deft Le Bar Bati, with prejudice, all claims and causes of action. The parties further stipulate that deft Le Bar Bat hereby withdraws its Motion for Summary Judgment dated 8/28/01, and no party will seek costs, sanctions, or attorneys fees against any other to this stipulation ( signed by Judge Robert W. Sweet ) (cd) (Entered: 11/06/2001)

SEALED DOCUMENT placed in vault. (wv) (Entered: 11/06/2001)

NOTICE of address change filed by E.E.O.C. . (yv) (Entered: 11/07/2001)

SEALED DOCUMENT placed in vault. (wv) (Entered: 11/07/2001)

ORDER; on October 4, 2001, defendant Die Fliedermaus filed a voluntary petition in Bankruptcy under Chapter 11 of the U.S. Bankruptcy Code ; Accordingly, the motion for an entry of judgment against defendant in the amount of $141,685.55 is dismissed as to Die Fliedermaus, L.L.C., and the action against it is dismissed with leave to renew at a later date without imposition of a filing fee . ( signed by Judge Robert W. Sweet ); Copies mailed. (djc) Modified on 11/09/2001 (Entered: 11/09/2001)

STIPULATION AND ORDER of dismissal; that all claims and causes of action of plaintiffs are dismissed with prejudice against defendant Le Bar Bat, Inc., only. Le Bar Bat hereby withdraws its Motion for Summary Judgment dated 8/28/01, and no party will seek costs, sanctions, or attorneys fees against any other to this stipulation. ( signed by Judge Robert W. Sweet ) (tp) Modified on 11/09/2001 (Entered: 11/09/2001)

NOTICE of change of addres by counsel for E.E.O.C. (kw) (Entered: 11/14/2001)

ORDER; that the Court's 9/5/01 Order is amended to include the following paragraph 2A; Due to the large number of depositions and voluminous document discovery pursued by the parties to this litigation, I hereby find that special circumstances exist such that defense counsel may file any motions for summary judgment on or before 12/3/01 and that the date for submission of the joint pretrial order by all parties is rescheduled to conference by 1/15/02 . ( signed by Judge Robert W. Sweet ); Copies mailed; orig. document docketed in 99cv2451 as document #50 (pl) (Entered: 11/14/2001)

ORDER; that Ross & Hardies may obtain copies of the transcripts of the depositions taken in 99cv1732 and 99cv2451 and use them in the sealed matter relating to Ross & Hardies' motion for fees and costs which is pending before this Court . ( signed by Judge Robert W. Sweet ); Copies mailed. (pl) (Entered: 11/13/2001)

Memo-Endorsement on letter addressed to Judge Sweet from Sunu P. Chandy, dated 10/5/01; granting the EEOC's request for a discovery extension until 2/19/02, and for the pretrial order to be due on 3/6/02 . ( signed by Judge Robert W. Sweet ); Copies mailed. (sn) (Entered: 11/20/2001)

Memo-Endorsement on letter addressed to Judge Sweet from Sunu P. Chandy, dated 10/5/01: Granting counsel for the EEOC requesting that the discovery deadline be extended until 2/19/02; and the pretrial order be due on 3/6/02 . ( signed by Judge Robert W. Sweet ); Copies mailed. (tp) (Entered: 11/27/2001)

NOTICE OF MOTION by E.E.O.C. for an order compelling defendant Die Fliedermaus, L.L.C. to comply with discovery obligations as further set forth in said motion . Declaration of Judy Keenan in support of motion attached. Return date 12/12/01. (db) (Entered: 12/06/2001)

MEMORANDUM OF LAW by E.E.O.C. in support of [69-1] motion for an order compelling defendant Die Fliedermaus, L.L.C. to comply with discovery obligations as further set forth in said motion. (db) (Entered: 12/06/2001)

STIPULATION; that Ross & Hardies application for fees against defendant Gerald J. Shallo, shall and hereby is discontinued in accordance with the settlement agreement reached between the parties; That Ross & Hardies' application for fees against defendant Die Fliedermaus LLC was dismissed by order of this Court dated 11/7/01. ( signed by Judge Robert W. Sweet ) (tp) (Entered: 12/17/2001)

MEMORANDUM OF LAW by Die Fliedermaus in opposition to [69-1] motion for an order compelling defendant Die Fliedermaus, L.L.C. to comply with discovery obligations as further set forth in said motion. (kkc) (Entered: 12/18/2001)

AFFIDAVIT of Annmarie P. Venuti by Die Fliedermaus in opposition to [69-1] motion for an order compelling defendant Die Fliedermaus, L.L.C. to comply with discovery obligations as further set forth in said motion. (kkc) (Entered: 12/18/2001)

AFFIDAVIT of Gerald J. Shallo by Die Fliedermaus in opposition to [69-1] motion for an order compelling defendant Die Fliedermaus, L.L.C. to comply with discovery obligations as further set forth in said motion. (kkc) (Entered: 12/18/2001)

DECLARATION of Judy Keenan by E.E.O.C. in support Re: [75-1] motion to compel discovery regarding affirmative defenses alleging that defendant Die Fliedermaus took prompt remedial action. (djc) (Entered: 03/05/2002)

Notice of Letter MOTION by E.E.O.C. to compel discovery regarding affirmative defenses alleging that defendant Die Fliedermaus took prompt remedial action . No Return date indicated. (db) (Entered: 01/25/2002)

MEMORANDUM OF LAW by Die Fliedermaus in opposition to [75-1] motion to compel discovery regarding affirmative defenses alleging that defendant Die Fliedermaus took prompt remedial action . (db) (Entered: 02/08/2002)

REPLY MEMORANDUM by E.E.O.C. in further support of [75-1] motion to compel discovery regarding affirmative defenses alleging that defendant Die Fliedermaus took prompt remedial action (db) (Entered: 02/15/2002)

Terminated document 49-1 pursuant to order of Judge Sweet as indicated on the CJRA report. (rag) (Entered: 02/28/2002)

REPLY MEMORANDUM by E.E.O.C. in Further Support of [75-1] motion to compel discovery regarding affirmative defenses alleging that defendant Die Fliedermaus took prompt remedial action; (djc) (Entered: 03/05/2002)

Letter filed by E.E.O.C. addressed to Judge Sweet from Sunu P. Chandy, dated 02/12/02; re: counsel requests an extension of discovery deadline; (djc) (Entered: 03/13/2002)

OPINION #86642, granting in part, denying in part [75-1] motion to compel discovery regarding affirmative defenses alleging that defendant Die Fliedermaus took prompt remedial action, and granting in part, denying in part [69-1] motion for an order compelling defendant Die Fliedermaus, L.L.C. to comply with discovery obligations as further set forth in said motion; the EEOC is permitted to continue discovery to the extent that it is consistent with the principles set forth in this opinion and 11 USC 362 of the Bankruptcy Code. The deadline for discovery will be extended for eight weeks from the date of this opinion . ( signed by Judge Robert W. Sweet ); Copies mailed. (kw) (Entered: 03/06/2002)

Notice of Letter MOTION by E.E.O.C. to compel discovery regarding affirmative defenses alleging that defendant Die Fliedermaus took prompt remedial action . Return date not indicated. Proposed order and exhibits attached. (moc) (Entered: 03/14/2002)

PRETRIAL CONFERENCE held before Judge Robert W. Sweet . (db) (Entered: 05/06/2002)

PRETRIAL CONFERENCE set at 6/25/02 before Judge Robert W. Sweet . (db) (Entered: 05/06/2002)

Memorandum to Docket Clerk: pre-trial conference held on 4/30/02 before Judge Sweet, next conference set for 6/25/02. (db) (Entered: 05/06/2002)

CONSENT JUDGMENT; This decree resolves the EEOC's claims as alleged in the complaint as futher set forth in this consent judgment. ( signed by Judge Robert W. Sweet ) Entered On Docket: 5/29/02. (jco) (Entered: 05/29/2002)

Case closed. (jco) (Entered: 05/29/2002)

STIPULATION of discontinuance; that on 11/98/01, dft. Simon Azoulay declared Chapter 7 Bankruptcy in the Eastern District Court of the State of New York bearing Docket No. 01-23948(DEM). In his petition for Bankruptcy, dft. Simon Azoulay scheduled the six plaintiffs as unsecured creditors based upon their having filed suit against him in this matter; the Bankruptcy case was fully administered and the Court granted a discharge without objection by any creditor on 2/19/02; because of the bankruptcy filing, it is understood that dft. Simon Azoulay has been discharged of any personal liability for the claims filed against him in the federal complaint except as provided by applicable federal and state law including, but not limited to, the Bankruptcy Code, and therefore on this basis plaintiff's hereby agree to discontinue this action against Simon Azoulay, with prejudice; dft. Simon Azoulay agrees that he will continue to submit himself to the jurisdiction of the Court only as agreeing to be treated as a party with regard to testifying at trial- i.e., he need not be subpoenaed as a witness for trial. He may attend the trial as if he still were a defendant. ( signed by Judge Robert W. Sweet ); (pl) Modified on 09/25/2002 (Entered: 09/23/2002)

RESPONSE AND OBJECTIONS to Interrogatories from Laurent M. Cerrone.Document filed by Laurent M. Cerrone.(db, ) Modified on 12/31/2003 (db, ). (Entered: 12/31/2003)