2022-cv-03395

COMPLAINT filed by Cynthia Gaspar; Jury Demand. Filing fee $ 402, receipt number AILNDC-19604724.

Civil Cover Sheet

MOTION by Defendant Pedersen & Houpt, P.C. to withdraw MOTION TO WITHDRAW THE APPEARANCES OF DONALD J. MORAN, RYAN LEE YOUNG, AND MARGARET ANN MILES

MINUTE entry before the Honorable Manish S. Shah: The motion to withdraw [13] is granted. Attorneys Ryan Lee Young, Margaret Ann Miles, and Donald J. Moran are terminated as counsel of record. Notices mailed.

MOTION by Defendant Pedersen & Houpt, P.C. for order Joint Motion for Entry of Agreed Confidentiality Order

AGREED CONFIDENTIALITY ORDER. Signed by the Honorable Manish S. Shah on 10/13/2022: The motion for entry of confidentiality order [15] is granted. Notices mailed.

ANNUAL REMINDER: Pursuant to Local Rule 3.2 (Notification of Affiliates), any nongovernmental party, other than an individual or sole proprietorship, must file a statement identifying all its affiliates known to the party after diligent review or, if the party has identified no affiliates, then a statement reflecting that fact must be filed. An affiliate is defined as follows: any entity or individual owning, directly or indirectly (through ownership of one or more other entities), 5% or more of a party. The statement is to be electronically filed as a PDF in conjunction with entering the affiliates in CM/ECF as prompted. As a reminder to counsel, parties must supplement their statements of affiliates within thirty (30) days of any change in the information previously reported. This minute order is being issued to all counsel of record to remind counsel of their obligation to provide updated information as to additional affiliates if such updating is necessary. If counsel has any questions regarding this process, this LINK will provide additional information. Signed by the Executive Committee on 12/29/2022: Mailed notice.

MOTION by Defendant Pedersen & Houpt, P.C. for leave to file Defendant's Motion for Leave to File a First Amended Answer and Affirmative Defenses to Plaintiff's Complaint

Exhibit A

MINUTE entry before the Honorable Manish S. Shah: The motion for leave to file an amended answer and affirmative defenses [21] is granted. Leave to amend should be freely given and the request came by the deadline set by the court's scheduling order. Defendant did not unduly delay the request for amendment, as it was based on relatively recent deposition testimony. The timing of the amendment will not unfairly prejudice plaintiff, because plaintiff has enough time to adapt deposition strategy in light of the amendment and because the amendment does not insert a factually complicated or novel issue into the case. Nor is the amendment futile; plaintiff may be right that the amendment is ineffectual because plaintiff has not attempted to expand the case beyond the EEOC charge or the complaint, but giving plaintiff notice that defendant would pursue affirmative defenses in the event the conduct at issue became relevant allows the parties to litigate the case with open eyes. To the extent defendant's amended affirmative defense is about after-acquired evidence, amendment to fit facts developed during discovery is not prejudicial, but is an ordinary consequence of the discovery process (and among the reasons the court sets a deadline for amendment of the pleadings toward the end of discovery). Defendant may file its amended answer and affirmative defenses as a separate entry on the docket. The parties' status report remains due 4/6/23. Notices mailed.

MOTION by Defendant Pedersen & Houpt, P.C. to stay Joint Motion to Stay Deposition Discovery, Vacate Deadlines, and Request Referral to Magistrate Judge for Settlement Conference

MINUTE entry before the Honorable Manish S. Shah: The motion to stay [25] is granted. Enter Referral to Magistrate Judge for Settlement Conference. Depositions and the discovery deadline are stayed and no status report is due 4/6/23. The parties shall file a status report on the progress of settlement discussions on 5/26/23. Notices mailed.