Case: EEOC v. SEGA OF AMERICA INC and SPHERION CORPORATION

Equal Employment Opportunity Commission v. Sega of America, Inc. et al

EEOC v. Sega of America et al

No Court

Carly Knight, Frank Dobbin, Alexandra Kalev

COMPLAINT summons issued against Sega of America, Inc., Spherion Corporation (Waived). Filed by Equal Employment Opportunity Commission. (ys, ) (Entered: 09/30/2002)

ADR SCHEDULING ORDER: Case Management Statement due by 1/24/2003. Case Management Conference set for 1/31/2003 at 02:00 PM.. Signed by Judge Susan Illston on 9/30/02. (ys, ) (Entered: 09/30/2002)

Summons Issued as to Sega of America, Inc. ; Spherion Corporation (ys, ) (Entered: 09/30/2002)

ANSWER to Complaint by Sega of America, Inc.. (ys, ) (Entered: 11/18/2002)

ANSWER to Complaint by Spherion Corporation. (ys, ) (Entered: 11/19/2002)

Received Document Stipulation and proposed order Selecting ADR process (Mediation) by Equal Employment Opportunity Commission, Sega of America, Inc., Spherion Corporation. (ys, ) (Entered: 01/09/2003)

STIPULATION AND ORDER Selecting ADR Process (Meditation). Signed by Judge Susan Illston on 1/9/03. (ys, ) (Entered: 01/10/2003)

ADR CLERK'S NOTICE OF APPOINTMENT OF MEDIATOR, Sanford Jay Rosen, dated 1/28/03. (af, ) (Entered: 01/28/2003)

Letter to parties dated 2/4/03 re: appointment, setting the pre-mediation telephone conference and stating disclosure(s), from Mediator, Sanford Jay Rosen. (af, ) (Entered: 02/05/2003)

JOINT CASE MANAGEMENT STATEMENT and proposed order filed by Equal Employment Opportunity Commission, Sega of America, Inc., Spherion Corporation. (ys, ) (Entered: 02/07/2003)

OBJECTIONS to Sanford Jay Rosen as court-appointed mediator submitted by letter dated 2/7/03 to ADR Unit from Cecily A. Waterman (cc: Sanford Jay Rosen, Cindy O'Hara, Katherine C. Huibonhoa) . (af, ) (Entered: 02/10/2003)

Letter acknowledging receipt of defendant Sega's objection to Sanford Jay Rosen as Mediator, ADR Unit to appoint another mediator as soon as possible from ADR Unit dated 2/10/03. (af, ) (Entered: 02/10/2003)

ADR CLERK'S NOTICE OF REMOVAL OF MEDIATOR, Sanford Jay Rosen and APPOINTMENT OF MEDIATOR, Laura Farrow, dated 2/10/03. (af, ). (Entered: 02/10/2003)

Letter dated 2/14/03 from Cecily A. Waterman, Esq. to the Court inquiring a determination as to whether non-party witnesses may be present at the deposition of another witness. (ys, ) (Entered: 02/20/2003)

Minute Entry: Initial Case Management Conference held on 2/18/2003 before Susan Illston. Further Case Management Conference set for 7/11/03 ; Motion due 10/31/03 ; Opp. 11/14/03 ; Reply 11/21/03 ; Motion hearing set for 12/5/03 at 9:00 a.m. ; Pretrial conference set for 3/23/04 at 9:00 a.m. ; Jury trial 4/5/04 at 8:30 a.m. (jury: 10 days) ; Discovery cutoff 8/29/03 ; Designation of experts by: pltf. 1/12/04 ; deft. 1/30/04 ; Rebuttal 2/13/04 ; Expert discovery cutoff 2/27/04. The defendants may jointly conduct 25 depositions. The Court granted defendant one day to depose Peck, two days to depose Amacon and Escalon. This case shall be referred to the Court's mediation program. The mediation session shall occur in June 2003 (Court Reporter None.) (ys, ) (Entered: 02/20/2003)

Set/Reset Deadlines:, Set/Reset Hearings: Case Management Conference set for 7/11/2003 at 02:30 PM. Discovery due by 8/29/2003. Motions due by 10/31/2003. Jury Trial set for 4/5/2004 08:30 AM. Motion Hearing set for 12/5/2003 09:00 AM. Pretrial Conference set for 3/23/2004 03:30 PM. (ys, ) (Entered: 02/20/2003)

NOTICE of entry of counsel, Raymond T. Cheung for plaintiff Equal Employment Opportunity Commission by Equal Employment Opportunity Commission. (ys, ) (Entered: 02/21/2003)

Letter Brief dated 2/21/03 from plaintiff's counsel Cindy O' Hara to the Court in opposition to the request for protective order by defendant Sega of American, Inc.. (ys, ) (Entered: 02/26/2003)

Letter dated 2/26/03 to parties setting mediation session for 6/19/03 at 10:00 a.m., at the Paul Hastings law office. Briefs due by 6/16/03 from Mediator, Laura Farrow. (af, ) (Entered: 02/27/2003)

Set/Reset Hearings: Mediation Hearing set for 6/19/2003 10:00 AM., in the law offices of Paul Hastings, et al., 55 Second St., 24th Floor, San Francisco. (af, ) (Entered: 03/25/2003)

Received Document Notice of substitution of counsel by Sega of America, Inc.. (ys, ) (Entered: 03/03/2003)

NOTICE of Substitution of Law Firm by Sega of America, Inc.. (ys, ) (Entered: 03/03/2003)

NOTICE of substitution of counsel by Sega of America, Inc.. (ys, ) (Entered: 03/06/2003)

ORDER granting substitution of attorneys from Brobeck, Phleger & Harrison LLP to Morgan, Lewis & bockius, LLP for defendant Sega of America, Inc.. . Signed by Judge Susan Illston on 3/3/03. (ys, ) (Entered: 03/06/2003)

CERTIFICATE/PROOF OF SERVICE by Sega of America, Inc. re [21] (ys, ) (Entered: 03/07/2003)

ORDER denying request for protective order. Signed by Judge Susan Illston on 3/13/03. (ys, ) (Entered: 03/17/2003)

Letter to counsel dated 5/19/03 resetting mediation sesstion to 7/24/03 at 10:00 a.m., written statements due by 7/21/03 from Mediator, Laura Farrow. (af, ) (Entered: 05/20/2003)

Set/Reset Hearings: Mediation Hearing set for 7/24/2003 10:00 AM., in the offices of Paul Hastings 55 Second St., 24th Fl., San Francisco. (af, ) (Entered: 05/20/2003)

STIPULATION AND ORDER by Judge Susan Illston that the date of court-connected mediation, which is set by the court's 2/19/03 pretrial preparation order as occurring in June 2003, be extended to occur 7/24/03, a date upon which all parties and the designated mediator have agreed. (gba) (Entered: 07/03/2003)

CLERK'S NOTICE: Case Management Conference set for 9/5/2003 at 02:30 PM. (gba) (Entered: 07/03/2003)

STIPULATION AND ORDER to extend discovery cutoff date. Non-expert discovery is extended to 12/31/03. Signed by Judge Susan Illston on 8/11/03. (ys, COURT STAFF) (Entered: 08/12/2003)

Set/Reset Deadlines: Discovery due by 12/31/2003. (ys, COURT STAFF) (Entered: 08/12/2003)

CERTIFICATION OF MEDIATION dated 8/11/2003, session held on 7/24/2003, case did not settle, no follow up contemplated. ADR process completed, filed by Mediator Laura Farrow. (af, ) (Entered: 08/15/2003)

Letter Brief regarding Discovery Disputes filed by Equal Employment Opportunity Commission. (ys, COURT STAFF) (Entered: 08/20/2003)

Letter dated 8/13/03 from Raymond T. Cheung, Esq. to Karen Peteros, Esq. re extension to the filing of opposition brief. (ys, COURT STAFF) (Entered: 08/20/2003)

JOINT CASE MANAGEMENT STATEMENT Second Joint Case Management Statement of Defendants Sega of America, Inc. and Spherion Corporation filed by Sega of America, Inc., Spherion Corporation. (Peteros, Karen) (Entered: 08/28/2003)

Second CASE MANAGEMENT STATEMENT filed by Equal Employment Opportunity Commission. (ys, COURT STAFF) (Entered: 08/29/2003)

DECLARATION of Cindy O'Hara in Support of plaintiff EEOC's Request for additiona time for the deposition of Julie Thompson filed by Equal Employment Opportunity Commission. (ys, COURT STAFF) (Entered: 08/29/2003)

Addendum toe [32] Second case management statement by Equal Employment Opportunity Commission. (ys, COURT STAFF) (Entered: 08/29/2003)

CERTIFICATE/PROOF OF SERVICE by Sega of America, Inc. of Sega's motion, including declaration of Karen H. Petersons in support of defendant Sega of America, Inc.s ' motion regarding deposition issues (ys, COURT STAFF) (Entered: 09/02/2003)

DECLARATION of Karen H. Peteros in Support Sega's Opposition to the EEOC's Motion/Request regarding deposition issues filed by Sega of America, Inc.. (ys, COURT STAFF) (Entered: 09/03/2003)

Letter dated 9/2/03 from Karen Peteros, Esq. to the Court re Sega's opposition to EEOC's August 13, 2003 letter motion re: Kirkham deposition issues & the EEOC's second CMC statement request re: Thompson deposition. (ys, COURT STAFF) (Entered: 09/05/2003)

Letter dated 9/2/03 from Karen Peteros, Esq. to the Court re Sega's opposition to EEOC's August 13, 2003 (letter) motion to compel regarding Sega's response to the EEOC's documents request & Sega's privilege log. (ys, COURT STAFF) (Entered: 09/05/2003)

Minute Entry: Further Case Management Conference held on 9/5/2003 before Susan Illston. Further Case Management Conference set for 12/19/03 at 2:30 p.m. ; Motions due 3/5/04 ; Opp. 3/19/04 ; Reply 3/26/04 ; Hearing for motions set for 4/9/04 at 9:00 a.m. ; Pretrial conference set for 9/7/04 at 3:30 p.m. ; Jury trial set for 9/20/04 at 8:30 a.m. (jury: 10 days) ; Discovery cutoff 12/31/03 ; Designation of experts by Pltf. 5/10/04 ; deft. 5/28/04 ; Rebuttal 6/11/04 ; Expert discovery cutoff 6/25/04. The Court adjusted the trial schedule as indicated above. Counsel had indicated that all of the discovery disputes re: depositions have been resolved and they will meet and confer re: the remaining issues. If the parties are not able to resolve the other disputes, they will bring that to the courts attention. Therefore the Court will not rule on counsel's 8/13/03, letter brief on these issues. The parties will go back to Judge Infante to further discuss settlement. (Court Reporter None.) (ys, COURT STAFF) (Entered: 09/09/2003)

Set/Reset Deadlines:, Set/Reset Hearings: Discovery due by 12/31/2003. Motions due by 3/5/2004. Case Management Conference set for 12/19/2003 at 02:30 PM. Jury Trial set for 9/20/2004 08:30 AM. Motion Hearing set for 4/9/2004 09:00 AM. Pretrial Conference set for 9/7/2004 03:30 PM. (ys, COURT STAFF) (Entered: 09/09/2003)

PRETRIAL PREPARATION ORDER: Further case management set for 12/19/30 at 2:30 p.m. ; Non-expert discovery cutoff 12/31/03 ; Designation of experts: pltf. 5/10/04; deft. 5/28/04 ; rebutttal designation 6/11/04 ; Expert discovery cutoff 6/25/04 ; Dispositive motions due 3/5/04 ; Opp. due 3/19/04 ; Reply due 3/26/04 ; hearing for motions set for 4/9/04 at 9:00 a.m. ; Pretrial conference set for 9/7/04 at 3:30 p.m. ; Jury trial set for 9/20/04 at 8:30 a.m. (trial length to be 10 days). The Court adjusted the trial schedule as indicated above. Counsel had indicated that all of the discovery disputes re: depositions have been resolved and they will meet and confer re: the remaining issues. If the parties are not able to resolve the other disputes, they will bring that to the courts attention. Therefore, the Court will not rule counsel's 8/13/03, letter brief on these issues. The parties will go back to Judge Infante to further discuss settlement. Signed by Judge Susan Illston on 9/8/03. (ys, COURT STAFF) (Entered: 09/09/2003)

Letter and exhibit dated 10/2/03 from defendant Sega of America, Inc.'s counsel, Karen H. Peteros to the Court re videotaping only part of the depositions of Julie Thompson & Deborah Kirkham. (ys, COURT STAFF) (Entered: 10/03/2003)

Letter dated 10/2/03 from plaintiff's counsel Cindy O'Hara to the Court in opposition to defendant Sega's failure to produce Julie Thompson for deposition, and objections to the videotaping of the Thompson and Kirkham depositions. (ys, COURT STAFF) (Entered: 10/03/2003)

ORDER re videotaping of depositions of Julie Thompson and Deborah Kirkham. The balance of the depositions shall no be video taped, since the first sessions were not. Sega shall pay to plaintiff EEOC the sum of $370.00. Signed by Judge Susan Illston on 10/2/03. (ys, COURT STAFF) (Entered: 10/03/2003)

Application for Substitution of Attorney Baker & McKenzie by Sega of America, Inc.. (Jackson, Cynthia) (Entered: 10/22/2003)

CLERK'S NOTICE re: Documents E-Filed in a case not designated for ECF (ys, COURT STAFF) (Entered: 10/23/2003)

CERTIFICATE/PROOF OF SERVICE by Sega of America, Inc. re 45 (ys, COURT STAFF) (Entered: 10/28/2003)

ORDER granting substitution of counsel. Signed by Judge Illston on 10/28/03. (ts, COURT STAFF) (Entered: 10/28/2003)

NOTICE of Change of Address by Equal Employment Opportunity Commission. (ys, COURT STAFF) (Entered: 11/05/2003)

Received Document Stipulation requesting to continue case management conference; order by Equal Employment Opportunity Commission. (ys, COURT STAFF) (Filed on 12/11/2003) (Entered: 12/12/2003)

Declaration of Cindy O'Hara in support of stipulation requesting to continue case management conference; order filed by Equal Employment Opportunity Commission. (ys, COURT STAFF) (Filed on 12/11/2003) (Entered: 12/12/2003)

Third JOINT CASE MANAGEMENT STATEMENT filed by defendants Sega of America, Inc., Spherion Corporation. (ys, COURT STAFF) (Filed on 12/12/2003) (Entered: 12/12/2003)

Declaration of Abiel K. Wong in Support of [51] Third joint case management statement filed by Sega of America, Inc., Spherion Corporation. (Related document(s)[51]) (ys, COURT STAFF) (Filed on 12/12/2003) (Entered: 12/12/2003)

Received Document Stipulated Miscellaneous Administrative Request to file file consent decree under temporary seal; stipulation; order by plaintiff Equal Employment Opportunity Commission. (ys, COURT STAFF) (Filed on 12/16/2003) (Entered: 12/17/2003)

Received Document by Equal Employment Opportunity Commission. (ys, COURT STAFF) (Filed on 12/16/2003) (Entered: 12/17/2003)

STIPULATION AND ORDER to continue case management conference to 1/30/04 at 2:30 p.m.. Signed by Judge Susan Illston on 12/16/03. (ys, COURT STAFF) (Filed on 12/17/2003) (Entered: 12/19/2003)

Set Deadlines/Hearings: Further Case Management Conference set for 1/30/2004 02:30 PM. (ys, COURT STAFF) (Filed on 12/17/2003) (Entered: 12/19/2003)

Letter from plaintiff's counsel Cindy O'Hara to the Court re consent decree. (ys, COURT STAFF) (Filed on 12/19/2003) (Entered: 12/23/2003)

STIPULATION AND ORDER granting miscellaneous administrative request to file consent decree under temporary seal. Signed by Judge Susan Illston on 12/17/03. (ys, COURT STAFF) (Filed on 12/19/2003) (Entered: 12/23/2003)

Document by Equal Employment Opportunity Commission. FILED UNDER TEMPORARY SEAL. (ys, COURT STAFF) (Filed on 12/22/2003) (Entered: 12/23/2003)

STIPULATION AND ORDER to extend discovery cutoff date. The date for completion of non-expert discovery is extended from 12/31/03 to 1/30/03. Signed by Judge Susan Illston on 12/24/03. (ys, COURT STAFF) (Filed on 12/24/2003) (Entered: 12/24/2003)

Set Deadlines/Hearings: Non-expert Discovery due by 1/30/2004. (ys, COURT STAFF) (Filed on 12/24/2003) (Entered: 12/24/2003)

NOTICE by Spherion Corporation Notice of Entry of Order to Extend Discovery Cutoff Date (Attachments: # 1 Exhibit Exhibit A to Notice of Entry of Order to Extend Discovery Cutoff Date)(Huibonhoa, Katherine) (Filed on 12/30/2003) (Entered: 12/30/2003)

CLERK'S NOTICE re: Documents E-Filed in a case not designated for ECF (NOTICE OF ENTRY OF ORDER TO EXTEND DISCOVERY CUTOFF DATE by defendant Spherion Corporation. (ys, COURT STAFF) (Filed on 12/31/2003) (Entered: 12/31/2003)

CERTIFICATE OF SERVICE by Equal Employment Opportunity Commission of Consent decree between the EEOC and Spherion Corporation, Stipulated miscellaneous administrative request to file consent decree under temporary seal;stipulation; order (ys, COURT STAFF) (Filed on 1/9/2004) (Entered: 01/09/2004)

Fourth CASE MANAGEMENT STATEMENT filed by Sega of America, Inc.. (ys, COURT STAFF) (Filed on 1/23/2004) (Entered: 01/26/2004)

Received Document Stipulation and proposed order requesting to continue case management conference and non-expert discovery cut-off pending lodging and entry of consent decree by Equal Employment Opportunity Commission, Sega of America, Inc., Spherion Corporation. (ys, COURT STAFF) (Filed on 1/29/2004) (Entered: 01/30/2004)

STIPULATION AND ORDER to continue case management conference and non-expert discovery cut-off pending lodging and entry of consent decree. Case management conference continued to 2/27/04 at 2:30 p.m., and the date for completion of non-expert discovery continued to 2/27/04. Signed by Judge Susan Illston on 2/3/04. (ys, COURT STAFF) (Filed on 2/4/2004) (Entered: 02/05/2004)

Received Document Stipulation and proposed order requesting to continue case management conference and non-expert discovery cut-off pending lodging and entry of consent decree by Equal Employment Opportunity Commission. (ys, COURT STAFF) (Filed on 2/26/2004) (Entered: 02/27/2004)

STIPULATION AND ORDER to continue case management conference to 3/5/04 at 2:30 and the due date of non-expert discovery to 3/5/04. Signed by Judge Susan Illston on 2/26/04. (ys, COURT STAFF) (Filed on 2/27/2004) (Entered: 03/01/2004)

Set Deadlines/Hearings: Non-expert Discovery due by 3/5/2004. Case Management Conference set for 3/5/2004 02:30 PM. (ys, COURT STAFF) (Filed on 2/27/2004) (Entered: 03/01/2004)

MOTION for Settlement determination barring claims for indemnification and contribution, and in the alternative, Good Faith Determination under Cal. Code Civil Procedure ss877 and Memorandum of Points and Authorities filed by Sega of America, Inc.. Motion Hearing set for 4/9/2004 09:00 AM. (ys, COURT STAFF) (Filed on 2/27/2004) (Entered: 03/01/2004)

Declaration of Cynthia L. Jackson in Support of [65] motions filed by Sega of America, Inc.. (Related document(s)[65]) (ys, COURT STAFF) (Filed on 2/27/2004) (Entered: 03/01/2004)

Proposed Order re [65] by Sega of America, Inc.. (ys, COURT STAFF) (Filed on 2/27/2004) (Entered: 03/01/2004)

Received Document Consent decree between the Equal Employment Opportunity Commission and Sega of America, Inc. by Equal Employment Opportunity Commission. (ys, COURT STAFF) (Filed on 3/2/2004) (Entered: 03/02/2004)

Letter dated 3/2/04 from plaintiff's counsel to the Court re parties Consent Decree. (ys, COURT STAFF) (Filed on 3/3/2004) (Entered: 03/04/2004)

ORDER: Consent Decree between the Equal Employment Opportunity Commission and Sega of America, Inc.. See Consent Decree for more details. Signed by Judge Susan Illston on 3/3/04. (ys, COURT STAFF) (Filed on 3/4/2004) (Entered: 03/05/2004)

Minute Entry: Further Case Management Conference held on 3/5/2004 before Susan Illston (Date Filed: 3/8/2004). The pretrial and trial date in this matter shall be vacated pending the settlement and motion that is scheduled to be heard on 4/9/04. (Court Reporter None.) (ys, COURT STAFF) (Date Filed: 3/8/2004) (Entered: 03/09/2004)

CERTIFICATE OF SERVICE by Equal Employment Opportunity Commission re Received Document Consent Decree between the EEOC and Sega of America, Inc.. (ys, COURT STAFF) (Filed on 3/11/2004) (Entered: 03/11/2004)

Letter dated 3/15/04 from Abiel K. Wong, Esq. to the Court withdrawing its motion for settlement determination barring claims for indemnification and contribution, and in alternative, good faith dtermination and requesting vacation of CMC set for 4/9/04.(ys, COURT STAFF) (Filed on 3/18/2004) (Entered: 03/18/2004)

Received Document Stipulation of dismissal with prejudice regarding defendant Sega of America, Inc. by Equal Employment Opportunity Commission, Sega of America, Inc.. (ys, COURT STAFF) (Filed on 3/28/2006) (Entered: 03/28/2006)

STIPULATION AND ORDER of Dismissal with prejudice regarding defendant Sega of America, Inc.. Signed by Judge Susan Illston on 3/30/06. (ys, COURT STAFF) (Filed on 3/31/2006) (Entered: 04/03/2006)

NOTICE of Entry of Order by Sega of America, Inc. re [72] Stipulation and Order. (ys, COURT STAFF) (Filed on 4/4/2006) (Entered: 04/05/2006)